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York, NY 10007 Re: The New York Times Co. v. Federal Bureau of Prisons, 20 Civ. 833 (PAE) Dear Judge Engelmayer: This Office represents defendant the Federal Bureau of Prisons ("BOP") in this Freedom of Information Act ("FOR"), 5 U.S.C. § 552, action brought by plaintiff the New York Times Company (the "Times") seeking th
te redactions. Pursuant to the Court's directions, the Government has, for each page, indicated which portions of the page are withheld under which FOIA Exemption and, if a portion or the entire page is withheld under FOIA Exemption 7(A), indicated which criminal case, United States v. Tartaglione, 16-cr- 832
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
iii EFTA00071587 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 5 of 25 PRELIMINARY STATEMENT This case involves records at the core of FOIA Exemption 7(A)—records that could reasonably be expected to interfere with two pending federal criminal prosecutions, one a death penalty case. The Bureau of
7 May 4, 2021 Re: The New York Times Co. v. Federal Bureau of Prisons, 20 Civ. 833 (PAE) Dear Judge Engelmayer: This Office represents defendant the Federal Bureau of Prisons ("BOP") in this Freedom of Information Act ("FOIA"), 5 U.S.C. § 552, action brought by plaintiff the New York Times Company (the "Times") seeking t
te redactions. Pursuant to the Court's directions, the Government has, for each page, indicated which portions of the page are withheld under which FOIA Exemption and, if a portion or the entire page is withheld under FOIA Exemption 7(A), indicated which criminal case, United States v. Tartaglione, 16-cr- 832
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
pecifically, this declaration addresses the bases for the withholding in whole or in part of certain records provided back to BOP by OIG pursuant to FOIA Exemption 7(A). Records Withheld in Full or in Part from Disclosure Pursuant to FOIA Exemption 7(A) on Account of Likely Interference with Noel 4. 5 U.S.C
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
iii EFTA00088608 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 5 of 25 PRELIMINARY STATEMENT This case involves records at the core of FOIA Exemption 7(A)—records that could reasonably be expected to interfere with two pending federal criminal prosecutions, one a death penalty case. The Bureau of
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
pecifically, this declaration addresses the bases for the withholding in whole or in part of certain records provided back to BOP by OIG pursuant to FOIA Exemption 7(A). Records Withheld in Full or in Part from Disclosure Pursuant to FOIA Exemption 7(A) on Account of Likely Interference with Noel 4. 5 U.S.C
York, NY 10007 Re: The New York Times Co. v. Federal Bureau of Prisons, 20 Civ. 833 (PAE) Dear Judge Engelmayer: This Office represents defendant the Federal Bureau of Prisons ("BOP") in this Freedom of Information Act ("FOR"), 5 U.S.C. § 552, action brought by plaintiff the New York Times Company (the "Times") seeking th
ages of emails. Pursuant to the Court's directions, the Government has, for each page, indicated which portions of the page are withheld under which FOIA Exemption and, if a portion or the entire page is withheld under FOIA Exemption 7(A), indicated which criminal case, United States v. Tartaglione, 16-cr-832
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
pecifically, this declaration addresses the bases for the withholding in whole or in part of certain records provided back to BOP by OIG pursuant to FOIA Exemption 7(A). Records Withheld in Full or in Part from Disclosure Pursuant to FOIA Exemption 7(A) on Account of Likely Interference with Noel 4. 5 U.S.C
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
iii EFTA00099601 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 5 of 25 PRELIMINARY STATEMENT This case involves records at the core of FOIA Exemption 7(A)—records that could reasonably be expected to interfere with two pending federal criminal prosecutions, one a death penalty case. The Bureau of
Entities connected to both Federal Bureau of Prisons and FOIA Exemption

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATIONSpecial Housing Unit
ORGANIZATIONthe Southern District
LOCATION
United States
LOCATIONNicholas Tartaglione
PERSONTova Noel
PERSONSouthern District
LOCATION
Audrey Strauss
PERSONAction Review
ORGANIZATION
The New York Times
ORGANIZATIONKearon
PERSON
Homeland Security
ORGANIZATION
THE NEW YORK TIMES COMPANY
ORGANIZATIONAldea & LoTurco
ORGANIZATION
White Plains
LOCATIONBruce Barket
PERSONChristenson
PERSON
Torres
PERSON