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nd withholding of the Returned Records have not substantially changed the legal issues to be resolved by the Court. The Supplemental Declaration of Nicole McFarland and the Supplemental Declaration of Kara Christenson also correct and clarify certain information discovered or determined since the Government's A
applies a more practical approach, the documents at issue were still compiled for law enforcement purposes. See BOP MOL at 8-10. Specifically, the Christenson and Supplemental Christenson declarations explain how the records were compiled to help BOP take "proactive steps designed to prevent criminal activ
the Central Office, individual staff at the MCC conducted searches for records responsive to the Times's request. As detailed in the Declaration of Nicole McFarland, BOP staff conferred to determine which MCC staff members would be likely to have records responsive to the Times's request and identified eight suc
termination that any responsive records were exempt from disclosure, in full or in part, under FOIA Exemptions 5, 6, 7(A), 7(C), 7(E), and/or 7(F). Christenson DecL ¶ 7. 3 EFTA00071562 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 10 of 30 The Times subsequently sent BOP two additional FOIA req
the Central Office, individual staff at the MCC conducted searches for records responsive to the Times's request. As detailed in the Declaration of Nicole McFarland, BOP staff conferred to determine which MCC staff members would be likely to have records responsive to the Times's request and identified eight suc
termination that any responsive records were exempt from disclosure, in full or in part, under FOIA Exemptions 5, 6, 7(A), 7(C), 7(E), and/or 7(F). Christenson DecL ¶ 7. 3 EFTA00075445 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 10 of 30 The Times subsequently sent BOP two additional FOIA req
nd withholding of the Returned Records have not substantially changed the legal issues to be resolved by the Court. The Supplemental Declaration of Nicole McFarland and the Supplemental Declaration of Kara Christenson also correct and clarify certain information discovered or determined since the Government's A
applies a more practical approach, the documents at issue were still compiled for law enforcement purposes. See BOP MOL at 8-10. Specifically, the Christenson and Supplemental Christenson declarations explain how the records were compiled to help BOP take "proactive steps designed to prevent criminal activ
the Central Office, individual staff at the MCC conducted searches for records responsive to the Times's request. As detailed in the Declaration of Nicole McFarland, BOP staff conferred to determine which MCC staff members would be likely to have records responsive to the Times's request and identified eight suc
termination that any responsive records were exempt from disclosure, in full or in part, under FOIA Exemptions 5, 6, 7(A), 7(C), 7(E), and/or 7(F). Christenson DecL ¶ 7. 3 EFTA00088679 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 10 of 30 The Times subsequently sent BOP two additional FOIA req
Entities connected to both Nicole McFarland and Christenson

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
Donald Trump
PERSON
Bloomberg L.P.
ORGANIZATION
United States
LOCATION
Julie K. Brown
PERSONLeon Black
PERSON
Prince Andrew
PERSONNicholas Tartaglione
PERSON
Supreme Court
ORGANIZATION
Ghislaine Maxwell
PERSON
George W. Bush
PERSONFederal Bureau of Prisons
ORGANIZATION
Doherty
PERSONTova Noel
PERSONthe Southern District
LOCATION
Metropolitan Correctional Center
ORGANIZATION
Audrey Strauss
PERSON
THE NEW YORK TIMES COMPANY
ORGANIZATIONShapiro
PERSON