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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
New York Times Co. v. Nat'l Aeronautics & Space Admin., 782 F. Supp. 628 (D.D.C. 1991) 12 NYCLU v. DNS, 771 F. Supp. 2d 289 (S.D.N.Y. 2011) 19 Radcliffe v. IRS, 536 F. Supp. 2d 423 (S.D.N.Y. 2008) 6 Summers v. DOJ, No. CV 98-1837(RWR), 2004 WL 7333532 (D.D.C. Apr. 14, 2004) 14 iii EFTA00071587
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
.2d 1088 (D.C. Cir. 1989) 8 Oglesby v. U.S. Army, 920 F.2d 57 (D.C. Cir. 1990) 5 Pinson v. Dept of .htstice, 236 F. Supp. 3d (D.D.C. 2017) 22 Radcliffe v. IRS, 536 F. Supp. 2d 423 (S.D.N.Y. 2008) 7, 8 Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., 421 U.S. 168 (1975) 13 Robbins, Geller, Ru
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
214, 227 (1978) 9, 10 NRDC v. EPA, 2019 U.S. Dist. LEXIS 124353 (S.D.N.Y. July 25, 2019) 20 Pratt v. Webster, 673 F.2d 408 (D.C. Cir. 1982) 9 Radcliffe v. IRS, 536 F. Supp. 2d 423 (S.D.N.Y. 2008) 10 United States v. Noel, No. 19-CR-00830-AT (S.D.N.Y. June 9, 2020) 13 U.S. Dep't of Justice v. Ta
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
.2d 1088 (D.C. Cir. 1989) 8 Oglesby v. U.S. Army, 920 F.2d 57 (D.C. Cir. 1990) 5 Pinson v. Dept of .htstice, 236 F. Supp. 3d (D.D.C. 2017) 22 Radcliffe v. IRS, 536 F. Supp. 2d 423 (S.D.N.Y. 2008) 7, 8 Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., 421 U.S. 168 (1975) 13 Robbins, Geller, Ru
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
New York Times Co. v. Nat'l Aeronautics & Space Admin., 782 F. Supp. 628 (D.D.C. 1991) 12 NYCLU v. DNS, 771 F. Supp. 2d 289 (S.D.N.Y. 2011) 19 Radcliffe v. IRS, 536 F. Supp. 2d 423 (S.D.N.Y. 2008) 6 Summers v. DOJ, No. CV 98-1837(RWR), 2004 WL 7333532 (D.D.C. Apr. 14, 2004) 14 iii EFTA00088608
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
214, 227 (1978) 9, 10 NRDC v. EPA, 2019 U.S. Dist. LEXIS 124353 (S.D.N.Y. July 25, 2019) 20 Pratt v. Webster, 673 F.2d 408 (D.C. Cir. 1982) 9 Radcliffe v. IRS, 536 F. Supp. 2d 423 (S.D.N.Y. 2008) 10 United States v. Noel, No. 19-CR-00830-AT (S.D.N.Y. June 9, 2020) 13 U.S. Dep't of Justice v. Ta
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
.2d 1088 (D.C. Cir. 1989) 8 Oglesby v. U.S. Army, 920 F.2d 57 (D.C. Cir. 1990) 5 Pinson v. Dept of .htstice, 236 F. Supp. 3d (D.D.C. 2017) 22 Radcliffe v. IRS, 536 F. Supp. 2d 423 (S.D.N.Y. 2008) 7, 8 Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., 421 U.S. 168 (1975) 13 Robbins, Geller, Ru
Entities connected to both Nicole McFarland and Radcliffe

Jeffrey Epstein
PERSONNicholas Tartaglione
PERSON
Human Rights Watch
ORGANIZATION
THE NEW YORK TIMES COMPANY
ORGANIZATION
United States
LOCATION
Metropolitan Correctional Center
ORGANIZATIOND.C. Cir
ORGANIZATION
Doherty
PERSON
The New York Times
ORGANIZATIONJudicial Watch, Inc.
ORGANIZATIONRobbins Tire & Rubber Co.
ORGANIZATION
Hopkins
ORGANIZATIONTova Noel
PERSONFavish
PERSONHomeland Sec
ORGANIZATION
Andrew Cuomo
PERSON
Alberto Gonzales
PERSONRussell Capone
PERSON
George W. Bush
PERSON
Audrey Strauss
PERSON