Epstein Secrets

Document 41 Filed 01/15/21 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK • THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. X 20 Civ. 833 (PAE) REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE FEDERAL BUREAU OF PRISONS'S MOTION FOR SUMMARY JUDGMENT AND IN

d Records The bases for BOP's withholdings in full or in part of certain Returned Records are set out in the Supplemental Declaration of Counsel to the Acting United States Attorney Russell Capone and the Supplemental Declaration of Kara Christenson. The bases for these withholdings are substantially the same as the ba

the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center ("MCC"). I am also familiar with the responsive records that defendant the Federal Bureau of Prisons ("BOP") has withheld in whole or in part pursuant to various FOIA exemptions, including BOP's withholdings from the records provided back to BOP by

intiff, No. 20-CV-833(PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. SUPPLEMENTAL DECLARATION OF hereby declare as follows: I. I am Counsel to the Acting United States Attorney for the Southern District of New York ("USAO-SDNY"). My prior declaration in this matter dated August 5, 2020, details my service in this

Document 41 Filed 01/15/21 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK • THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. X 20 Civ. 833 (PAE) REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE FEDERAL BUREAU OF PRISONS'S MOTION FOR SUMMARY JUDGMENT AND IN

d Records The bases for BOP's withholdings in full or in part of certain Returned Records are set out in the Supplemental Declaration of Counsel to the Acting United States Attorney Russell Capone and the Supplemental Declaration of Kara Christenson. The bases for these withholdings are substantially the same as the ba

the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center ("MCC"). I am also familiar with the responsive records that defendant the Federal Bureau of Prisons ("BOP") has withheld in whole or in part pursuant to various FOIA exemptions, including BOP's withholdings from the records provided back to BOP by

HE NEW YORK TIMES COMPANY. Plaintiff, No. 20-CV-833(PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. reby declare as follows: I. I am Counsel to the Acting United States Attorney for the Southern District of New York ("USAO-SDNY"). My prior declaration in this matter dated August 5, 2020, details my service in this

o the best of my knowledge and belief. Executed this 15th day of January 2021. Government Information Specialist FOIAJPA Section (Central Office) Bureau of Prisons 18 EFTA00099640

of Epstein's medical records, but withheld in full 12 pages for reasons explained at Paragraph 20 of the August 5, 2020, declaration of Counsel to the Acting United States Attorney Russell Capone. 14. The Updated Index corrects an inadvertent error that resulted in double counting of seventeen pages of emails listed

the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center ("MCC"). I am also familiar with the responsive records that defendant the Federal Bureau of Prisons ("BOP") has withheld in whole or in part pursuant to various FOIA exemptions, including BOP's withholdings from the records provided back to BOP by

ff, No. 20-CV-833(PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. SUPPLEMENTAL DECLARATION OF I, hereby declare as follows: I. I am Counsel to the Acting United States Attorney for the Southern District of New York ("USAO-SDNY"). My prior declaration in this matter dated August 5, 2020, details my service in this

AE Document 41 Filed 01/15/21 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. X 20 Civ. 833 (PAE) REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE FEDERAL BUREAU OF PRISONS'S MOTION FOR SUMMARY JUDGMENT AND IN

d Records The bases for BOP's withholdings in full or in part of certain Returned Records are set out in the Supplemental Declaration of Counsel to the Acting United States Attorney' and the Supplemental Declaration o . The bases for these withholdings are substantially the same as the bases for BOP's prior withholdin