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

han recite the boilerplate rationale for protecting deliberative documents. (Gov't Reply Br., at 17-18.) That is not enough. In order to satisfy the Amendment's standard, BOP "must explain how a particular Exemption 5 withholding would harm [its] deliberative process." Nat? Day Laborer Org. Network v. U.S

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

han recite the boilerplate rationale for protecting deliberative documents. (Gov't Reply Br., at 17-18.) That is not enough. In order to satisfy the Amendment's standard, BOP "must explain how a particular Exemption 5 withholding would harm [its] deliberative process." Nat? Day Laborer Org. Network v. U.S

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

han recite the boilerplate rationale for protecting deliberative documents. (Gov't Reply Br., at 17-18.) That is not enough. In order to satisfy the Amendment's standard, BOP "must explain how a particular Exemption 5 withholding would harm [its] deliberative process." Nat? Day Laborer Org. Network v. U.S