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

lized. See Supp. Christenson Decl. ¶ 16. These prior versions of the ultimate response document were properly withheld under Exemption 5 as drafts. See American Civil Liberties Union v. Dep't ofJustice, 844 F.3d 126, 133 (2d Cir. 2016); Amnesty Int'l USA v. CIA, 728 F. Supp. 2d 479, 518 (S.D.N.Y. 2010) ("It is well- settled that

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

lized. See Supp. Christenson Decl. ¶ 16. These prior versions of the ultimate response document were properly withheld under Exemption 5 as drafts. See American Civil Liberties Union v. Dep't ofJustice, 844 F.3d 126, 133 (2d Cir. 2016); Amnesty Int'l USA v. CIA, 728 F. Supp. 2d 479, 518 (S.D.N.Y. 2010) ("It is well- settled that

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

it was finalized. See Supp. Decl. ¶ 16. These prior versions of the ultimate response document were properly withheld under Exemption 5 as drafts. See American Civil Liberties Union v. Dep't ofJustice, 844 F.3d 126, 133 (2d Cir. 2016); Amnesty Int'l USA v. CIA, 728 F. Supp. 2d 479, 518 (S.D.N.Y. 2010) ("It is well- settled that