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

gh such use of such items was generally known). Here, for example, certain of the reports prepared during the course of BOP's investigation include Security Threat Group ("STG") designations, which are an enhanced monitoring technique used by BOP. See Supp. Christenson Decl. ¶¶ 20, 23. As another example, the August

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

gh such use of such items was generally known). Here, for example, certain of the reports prepared during the course of BOP's investigation include Security Threat Group ("STG") designations, which are an enhanced monitoring technique used by BOP. See Supp. Christenson Decl. ¶¶ 20, 23. As another example, the August

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

gh such use of such items was generally known). Here, for example, certain of the reports prepared during the course of BOP's investigation include Security Threat Group ("STG") designations, which are an enhanced monitoring technique used by BOP. See Supp. Decl. ¶¶ 20, 23. As another example, the August 14, 2019 l