Epstein Secrets

men — And He Didn't Kill Himself, Brother Says, Miami Herald (Nov. 14, 2019) 6 U.S. Dep't ofJustice Federal Bureau of Prisons, Attorney's Guide to the Metropolitan Correctional Center New York, New York (2008) 6 U.S. Dep't ofJustice Nat'l Inst. of Corrections, National Study of Jail Suicide: 20 Years Later (Apr. 2010) 9, 10 U.S. Dep't

3 (PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. X REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT David E. McCraw Al-Amyn Sumar Alexandra Settelmayer The New York Times Company Legal Department 620 Eighth Avenue New York, NY 10018 Phone: 212-556-4031 Facs

men — And He Didn't Kill Himself, Brother Says, Miami Herald (Nov. 14, 2019) 6 U.S. Dep't ofJustice Federal Bureau of Prisons, Attorney's Guide to the Metropolitan Correctional Center New York, New York (2008) 6 U.S. Dep't ofJustice Nat'l Inst. of Corrections, National Study of Jail Suicide: 20 Years Later (Apr. 2010) 9, 10 U.S. Dep't

3 (PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. X REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT David E. McCraw Al-Amyn Sumar Alexandra Settelmayer The New York Times Company Legal Department 620 Eighth Avenue New York, NY 10018 Counsel for Plaintiff EF

RELIMINARY STATEMENT Financier Jeffrey Epstein's suicide in August 2019, and subsequent revelations about what Attorney General William Barr called the Metropolitan Correctional Center's (MCC) "failure to adequately secure this prisoner," led to widespread calls for accountability and reform. Ali Watkins, Katie Benner & Danielle Ivo

X MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT AND IN OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT David E. McCraw Al-Amyn Sumar Alexandra Perloff-Giles The New York Times Company Legal Department Counsel for Plaintiff EFTA00071624 Case 1:20-cv-00833-PAE D

uests properly made by Plaintiff. 2. The records concern Jeffrey Epstein, the wealthy financier charged with sex trafficking of minors who died at the Metropolitan Correctional Center ("MCC") on August 10, 2019. Epstein's relationships with prominent figures in politics, business, and Hollywood entertainment contribute to the pub

FOIA; and 33. Grant Plaintiff such other and further relief as this Court deems just and proper. Dated: New York, New York January 30, 2020 /s/ David E. McCraw David E. McCraw Alexandra Perloff-Giles 6 EFTA00074145 Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 7 of 7 Legal Department The New

men — And He Didn't Kill Himself, Brother Says, Miami Herald (Nov. 14, 2019) 6 U.S. Dep't ofJustice Federal Bureau of Prisons, Attorney's Guide to the Metropolitan Correctional Center New York, New York (2008) 6 U.S. Dep't ofJustice Nat'l Inst. of Corrections, National Study of Jail Suicide: 20 Years Later (Apr. 2010) 9, 10 U.S. Dep't

3 (PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. X REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT David E. McCraw Al-Amyn Sumar Alexandra Settelmayer The New York Times Company Legal Department 620 Eighth Avenue New York, NY 10018 Counsel for Plaintiff EF

RELIMINARY STATEMENT Financier Jeffrey Epstein's suicide in August 2019, and subsequent revelations about what Attorney General William Barr called the Metropolitan Correctional Center's (MCC) "failure to adequately secure this prisoner," led to widespread calls for accountability and reform. Ali Watkins, Katie Benner & Danielle Ivo

X MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT AND IN OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT David E. McCraw Al-Amyn Sumar Alexandra Perloff-Giles The New York Times Company Legal Department 620 Eighth Avenue New York, NY 10018 Phone: 212-556-4031 Fa

uests properly made by Plaintiff. 2. The records concern Jeffrey Epstein, the wealthy financier charged with sex trafficking of minors who died at the Metropolitan Correctional Center ("MCC") on August 10, 2019. Epstein's relationships with prominent figures in politics, business, and Hollywood entertainment contribute to the pub

FOIA; and 33. Grant Plaintiff such other and further relief as this Court deems just and proper. Dated: New York, New York January 30, 2020 /s/ David E. McCraw David E. McCraw Alexandra Perloff-Giles 6 EFTA00091291 Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 7 of 7 Legal Department The New

uests properly made by Plaintiff. 2. The records concern Jeffrey Epstein, the wealthy financier charged with sex trafficking of minors who died at the Metropolitan Correctional Center ("MCC") on August 10, 2019. Epstein's relationships with prominent figures in politics, business, and Hollywood entertainment contribute to the pub

FOIA; and 33. Grant Plaintiff such other and further relief as this Court deems just and proper. Dated: New York, New York January 30, 2020 /s/ David E. McCraw David E. McCraw Alexandra Perloff-Giles 6 EFTA00094146 Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 7 of 7 Legal Department The New

uests properly made by Plaintiff. 2. The records concern Jeffrey Epstein, the wealthy financier charged with sex trafficking of minors who died at the Metropolitan Correctional Center ("MCC") on August 10, 2019. Epstein's relationships with prominent figures in politics, business, and Hollywood entertainment contribute to the pub

FOIA; and 33. Grant Plaintiff such other and further relief as this Court deems just and proper. Dated: New York, New York January 30, 2020 /s/ David E. McCraw David E. McCraw Alexandra Perloff-Giles 6 EFTA00095065 Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 7 of 7 Legal Department The New

uests properly made by Plaintiff. 2. The records concern Jeffrey Epstein, the wealthy financier charged with sex trafficking of minors who died at the Metropolitan Correctional Center ("MCC") on August 10, 2019. Epstein's relationships with prominent figures in politics, business, and Hollywood entertainment contribute to the pub

FOIA; and 33. Grant Plaintiff such other and further relief as this Court deems just and proper. Dated: New York, New York January 30, 2020 /s/ David E. McCraw David E. McCraw Alexandra Perloff-Giles 6 EFTA00098064 Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 7 of 7 Legal Department The New