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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
pp. 2d 37 (D.D.C. 2012) 14 Judicial Watch, Inc. v. U.S. Dep't of Commerce, 337 F. Supp. 2d 146 (D.D.C. 2004) 20 Kimberlin v. DOJ, 139 F.3d 944 (D.C. Cir. 1998) 13 Knight First Amendment Institute at Columbia Univ. v. U. S. Dep't of Homeland Security, 407 F. Supp. 3d 334 (S.D.N.Y. 2019) 19 Kubik
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
, 2 00 7) 15 National Archives & Records Administration v. Favish, 541 U.S. 157 (200 4) 19 Nat 7 Assoc. of Homebuilders v. Norton, 309 F.3d 26 (D.C. Cir. 2 002) 17 iii EFTA00071557 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 5 of 30 New York Tunes Co. v. Dep't o/•.Justice, No. 14 Ch,
l (`OIG') on or about August 22, 2019," and therefore "the BOP is no longer in possession of the log books" (Christenson Decl. 1 13; Declaration of Nicole McFarland, ECF No. 23 [hereinafter "McFarland Decl."], at ¶ 8). But, as BOP concedes, BOP received a FOIA request from The Times on August 13, 2019, seeking
the Air Force, 566 F.2d 242 (1977) 6 Meyer v. Bush, 1991 U.S. Dist. LEXIS 13626 (D.D.C. Sept. 30, 1991), rev'd on other grounds, 981 F.2d 1288 (D.C. Cir. 1993) 7 Morley v. C.I.A., 508 F.3d 1108 (D.C. Cir. 2007) 14 Multi Ag Media LLC v. Dep't ofAgric., 515 F.3d 1224 (D.C. Cir. 2008) 14 N.Y. Tim
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
, 2 00 7) 15 National Archives & Records Administration v. Favish, 541 U.S. 157 (200 4) 19 Nat 7 Assoc. of Homebuilders v. Norton, 309 F.3d 26 (D.C. Cir. 2 002) 17 iii EFTA00075440 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 5 of 30 New York Tunes Co. v. Dep't o/•.Justice, No. 14 Ch,
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
pp. 2d 37 (D.D.C. 2012) 14 Judicial Watch, Inc. v. U.S. Dep't of Commerce, 337 F. Supp. 2d 146 (D.D.C. 2004) 20 Kimberlin v. DOJ, 139 F.3d 944 (D.C. Cir. 1998) 13 Knight First Amendment Institute at Columbia Univ. v. U. S. Dep't of Homeland Security, 407 F. Supp. 3d 334 (S.D.N.Y. 2019) 19 Kubik
l (`OIG') on or about August 22, 2019," and therefore "the BOP is no longer in possession of the log books" (Christenson Decl. 1 13; Declaration of Nicole McFarland, ECF No. 23 [hereinafter "McFarland Decl."], at ¶ 8). But, as BOP concedes, BOP received a FOIA request from The Times on August 13, 2019, seeking
the Air Force, 566 F.2d 242 (1977) 6 Meyer v. Bush, 1991 U.S. Dist. LEXIS 13626 (D.D.C. Sept. 30, 1991), rev'd on other grounds, 981 F.2d 1288 (D.C. Cir. 1993) 7 Morley v. C.I.A., 508 F.3d 1108 (D.C. Cir. 2007) 14 Multi Ag Media LLC v. Dep't ofAgric., 515 F.3d 1224 (D.C. Cir. 2008) 14 N.Y. Tim
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
, 2 00 7) 15 National Archives & Records Administration v. Favish, 541 U.S. 157 (200 4) 19 Nat 7 Assoc. of Homebuilders v. Norton, 309 F.3d 26 (D.C. Cir. 2 002) 17 iii EFTA00088674 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 5 of 30 New York Tunes Co. v. Dep't o/•.Justice, No. 14 Ch,
Entities connected to both Nicole McFarland and D.C. Cir

Jeffrey Epstein
PERSON
United States
LOCATION
George W. Bush
PERSONthe Southern District
LOCATIONLeon Black
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Supreme Court
ORGANIZATIONNicholas Tartaglione
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Department of Justice
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Julie K. Brown
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ORGANIZATIONRadcliffe
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Alan Dershowitz
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Ghislaine Maxwell
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Alberto Gonzales
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PERSONTova Noel
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The New York Times
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