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

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

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

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

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

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

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

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

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

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

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

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

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

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