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ted at the Metropolitan Correctional Center ("MCC") until his death. Declaration of Russell Capone, Counsel to the Acting United States Attorney for the Southern District of New York ("Capone Declaration") ¶ 4; see Docket Entry dated July 8, 2019, United States v. Epstein, No. 19-cr-490 (RMB) (S.D.N.Y.). On July 23,
. The Times's FOIA Requests and This Action 3 ARGUMENT 4 I. FOIA and the Summary Judgment Standard 4 II. BOP Conducted an Adequate Search for Responsive Records 5 III. BOP's Withholdings Were Proper 6 IV. BOP Has Satisfied Its Duty to Segregate and Release Any Non-Exempt Information. 22 CONCLUSION 23
ted at the Metropolitan Correctional Center ("MCC") until his death. Declaration of Russell Capone, Counsel to the Acting United States Attorney for the Southern District of New York ("Capone Declaration") ¶ 4; see Docket Entry dated July 8, 2019, United States v. Epstein, No. 19-cr-490 (RMB) (S.D.N.Y.). On July 23,
. The Times's FOIA Requests and This Action 3 ARGUMENT 4 I. FOIA and the Summary Judgment Standard 4 II. BOP Conducted an Adequate Search for Responsive Records 5 III. BOP's Withholdings Were Proper 6 IV. BOP Has Satisfied Its Duty to Segregate and Release Any Non-Exempt Information. 22 CONCLUSION 23
ted at the Metropolitan Correctional Center ("MCC") until his death. Declaration of Russell Capone, Counsel to the Acting United States Attorney for the Southern District of New York ("Capone Declaration") ¶ 4; see Docket Entry dated July 8, 2019, United States v. Epstein, No. 19-cr-490 (RMB) (S.D.N.Y.). On July 23,
. The Times's FOIA Requests and This Action 3 ARGUMENT 4 I. FOIA and the Summary Judgment Standard 4 II. BOP Conducted an Adequate Search for Responsive Records 5 III. BOP's Withholdings Were Proper 6 IV. BOP Has Satisfied Its Duty to Segregate and Release Any Non-Exempt Information. 22 CONCLUSION 23
Entities connected to both the Southern District and Responsive Records

Jeffrey Epstein
PERSON
United States
LOCATION
George W. Bush
PERSON
Supreme Court
ORGANIZATION
Audrey Strauss
PERSON
Metropolitan Correctional Center
ORGANIZATIONGarcia
PERSON
Alberto Gonzales
PERSONSpecial Housing Unit
ORGANIZATION
Sarah Ferguson
PERSONRagen
PERSON
The New York Times
ORGANIZATION
Andrew Cuomo
PERSON
H.R.
PERSON
The Washington Post
ORGANIZATIONTova Noel
PERSONNicholas Tartaglione
PERSONthe Second Circuit's
ORGANIZATIONCarney
PERSONMichael Thomas
PERSON