Epstein Secrets

6, 2019, he was arrested and charged by federal prosecutors and thereafter incarcerated at the MCC. (Id.) On July 10, 2019, Epstein was assigned to the Special Housing Unit ("SHU'), at least in part because of the risk of suicidal ideation. (Id. 1 5.) Nonetheless, on July 23, 2019, Epstein was found on the floor of his

ORT 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 Document 27 Filed 09/10/20 Page 2 of 29

12. A second subset focused on the operations of the MCC during the time of Epstein's attempted suicide and, later, his death: "The signed log in the Special Housing Unit at MCC that shows when prison staff did rounds on July 22 and 23, and Aug. 9 and 10"; "The overtime sign-up sheets for the Special Housing Unit (9

uch 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 York Times Company 620 8th Avenue New Yo

6, 2019, he was arrested and charged by federal prosecutors and thereafter incarcerated at the MCC. (Id.) On July 10, 2019, Epstein was assigned to the Special Housing Unit ("SHU'), at least in part because of the risk of suicidal ideation. (Id. 1 5.) Nonetheless, on July 23, 2019, Epstein was found on the floor of his

ORT 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 Facsimile: (212) 556-4634 Email: mccraw@n

12. A second subset focused on the operations of the MCC during the time of Epstein's attempted suicide and, later, his death: "The signed log in the Special Housing Unit at MCC that shows when prison staff did rounds on July 22 and 23, and Aug. 9 and 10"; "The overtime sign-up sheets for the Special Housing Unit (9

uch 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 York Times Company 620 8th Avenue New Yo

12. A second subset focused on the operations of the MCC during the time of Epstein's attempted suicide and, later, his death: "The signed log in the Special Housing Unit at MCC that shows when prison staff did rounds on July 22 and 23, and Aug. 9 and 10"; "The overtime sign-up sheets for the Special Housing Unit (9

uch 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 York Times Company 620 8th Avenue New Yo

12. A second subset focused on the operations of the MCC during the time of Epstein's attempted suicide and, later, his death: "The signed log in the Special Housing Unit at MCC that shows when prison staff did rounds on July 22 and 23, and Aug. 9 and 10"; "The overtime sign-up sheets for the Special Housing Unit (9

uch 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 York Times Company 620 8th Avenue New Yo

12. A second subset focused on the operations of the MCC during the time of Epstein's attempted suicide and, later, his death: "The signed log in the Special Housing Unit at MCC that shows when prison staff did rounds on July 22 and 23, and Aug. 9 and 10"; "The overtime sign-up sheets for the Special Housing Unit (9

uch 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 York Times Company 620 8th Avenue New Yo

19." See Attachment 1, Plaintiff's FOIA request dated August 13, 2019. Specifically, Plaintiff sought the following records: (1) The signed log in the Special Housing Unit at MCC that shows when prison staff did rounds on July 22 and 23, and Aug. 9 and 10; (2) All quarter entries (showing which cells he was housed in

.S. Department of Justice Office of Information Policy Suite 11050 1425 New York Avenue, NW Washington, DC 20530.0001 Telephone: (202) 514-3642 Alexandra Perloff-Giles, Esq. The New York Times Company 620 8th Avenue Re: Appeal No. DOJ-AP-2020-000123 New York, NY 10018 Request No. 2019-05665 aperloffgiles@nyti