Epstein Secrets

RAL BUREAU OF PRISONS, Defendant. X REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT David E. McCraw Al-Amyn Sumar Alexandra Settelmayer The New York Times Company Legal Department 620 Eighth Avenue New York, NY 10018 Counsel for Plaintiff EFTA00071609 Ca

to the defendants—they fall short of actually connecting these specific types of records to any of those concerns. (See Capone Decl. 18-22, 24-25; Supplemental Decl. of Russell Capone, ECF No. 40 [hereinafter "Capone Supp. Decl."], at ¶¶ 6-7, 10-13). Generic concerns that some administrative documents in some ca

RAL BUREAU OF PRISONS, Defendant. X REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT David E. McCraw Al-Amyn Sumar Alexandra Settelmayer The New York Times Company Legal Department 620 Eighth Avenue New York, NY 10018 Counsel for Plaintiff EFTA00088560 Ca

age to the defendants—they fall short of actually connecting these specific types of records to any of those concerns. (See Decl. ¶¶ 18-22, 24-25; Supplemental Decl. of Russell ECF No. 40 [hereinafter a Supp. Decl."], at ¶¶ 6-7, 10-13). Generic concerns that some administrative documents in some cases may int

RAL BUREAU OF PRISONS, Defendant. X REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT David E. McCraw Al-Amyn Sumar Alexandra Settelmayer The New York Times Company Legal Department 620 Eighth Avenue New York, NY 10018 Phone: 212-556-4031 Facsimile: (212) 55

to the defendants—they fall short of actually connecting these specific types of records to any of those concerns. (See Capone Decl. 18-22, 24-25; Supplemental Decl. of Russell Capone, ECF No. 40 [hereinafter "Capone Supp. Decl."], at ¶¶ 6-7, 10-13). Generic concerns that some administrative documents in some ca