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

t 1, United States v. Noel, No. 19-cr-830 (AT) (S.D.N.Y.), Dkt. No. 22; Memorandum of Law of the United States of America in Opposition to Defendant Michael Thomas's Motion to Compel, United States v. Noel, at 8-9, No. 19-cr-830 (AT) (S.D.N.Y.), Dkt. No. 35. The fact that materials at issue have been disclosed t

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

t 1, United States v. Noel, No. 19-cr-830 (AT) (S.D.N.Y.), Dkt. No. 22; Memorandum of Law of the United States of America in Opposition to Defendant Michael Thomas's Motion to Compel, United States v. Noel, at 8-9, No. 19-cr-830 (AT) (S.D.N.Y.), Dkt. No. 35. The fact that materials at issue have been disclosed t

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

t 1, United States v. Noel, No. 19-cr-830 (AT) (S.D.N.Y.), Dkt. No. 22; Memorandum of Law of the United States of America in Opposition to Defendant Michael Thomas's Motion to Compel, United States v. Noel, at 8-9, No. 19-cr-830 (AT) (S.D.N.Y.), Dkt. No. 35. The fact that materials at issue have been disclosed t

veral additional standards of conduct on its employees. At all times, BOP employees must "[c]onduct themselves in a manner that fosters respect for the Bureau of Prisons, the Department of Justice, and the U.S. Government." Because "[i]nattention to duty in a correctional environment can result in escapes, assaults,

not observe on the recorded video any CO or other individual enter any of the SHU tiers, which is consistent with CO Tova Noel and Material Handler Michael Thomas's admissions to the OIG that the SHU rounds and counts were not conducted during that time frame. At approximately 6:28 a.m., an unidentified officer

veral additional standards of conduct on its employees. At all times, BOP employees must "[c]onduct themselves in a manner that fosters respect for the Bureau of Prisons, the Department of Justice, and the U.S. Government." Because "[i]nattention to duty in a correctional environment can result in escapes, assaults,

not observe on the recorded video any CO or other individual enter any of the SHU tiers, which is consistent with CO Tova Noel and Material Handler Michael Thomas's admissions to the OIG that the SHU rounds and counts were not conducted during that time frame. At approximately 6:28 a.m., an unidentified officer