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ded "greater access to agency investigatory files" that would bear on the prosecution than he would under the rules of criminal procedure. New York Times Co. v. Dep't of Justice, 390 F. Supp. 3d 499, 512 (S.D.N.Y. 2019). But, as to least one important category, emails of Tartaglione's counsel, he already
Case 1:20-cv-00833-PAE Document 42 Filed 02/10/21 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, No. 20-cv-00833 (PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. X REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFF'S CROSS-
ded "greater access to agency investigatory files" that would bear on the prosecution than he would under the rules of criminal procedure. New York Times Co. v. Dep't of Justice, 390 F. Supp. 3d 499, 512 (S.D.N.Y. 2019). But, as to least one important category, emails of Tartaglione's counsel, he already
Case 1:20-cv-00833-PAE Document 42 Filed 02/10/21 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, No. 20-cv-00833 (PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. X REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFF'S CROSS-
ded "greater access to agency investigatory files" that would bear on the prosecution than he would under the rules of criminal procedure. New York Times Co. v. Dep't ofJustice, 390 F. Supp. 3d 499, 512 (S.D.N.Y. 2019). But, as to least one important category, emails of Tartaglione's counsel, he already h
Case 1:20-cv-00833-PAE Document 42 Filed 02/10/21 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, No. 20-cv-00833 (PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. X REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFF'S CROSS-
Entities connected to both Times Co. and THE NEW YORK TIMES COMPANY

Jeffrey Epstein
PERSON
Metropolitan Correctional Center
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATIONNicholas Tartaglione
PERSONthe Southern District
LOCATION
The New York Times
ORGANIZATION
Human Rights Watch
ORGANIZATIONRadcliffe
PERSOND.C. Cir
ORGANIZATIONDavid E. McCraw
PERSONHomeland Sec
ORGANIZATION
Alberto Gonzales
PERSON
Andrew Cuomo
PERSONRussell Capone
PERSONKara Christenson
PERSONU.S. Dept of Commerce
ORGANIZATIONShapiro
PERSONTimothy Dalton Vaughn
PERSON
Julie K. Brown
PERSONChristina Goldbaum
PERSON