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ption 5, the deliberative process privilege "does not operate indiscriminately to shield all decision-making by public officials." N.Y. Times Co. v. Dep't of Def., 499 F. Supp. 2d 501, 514 (S.D.N.Y. 2007). Moreover, the Government's Exemption 5 withholdings cannot survive because BOP has failed to meet
rehensive guidance as to how a BOP staff member should respond to an inmate's suicide attempt. See U.S. Dep't of Justice Nat'l Inst. of Corrections, National Study ofJail Suicide: 20 Years Later (Apr. 2010), at 52, https://bitly/31YuolCm (discussing the three requisite 9 EFTA00105611 Case 1:20-cv-00833-PAE
ption 5, the deliberative process privilege "does not operate indiscriminately to shield all decision-making by public officials." N.Y. Times Co. v. Dep't of Def., 499 F. Supp. 2d 501, 514 (S.D.N.Y. 2007). Moreover, the Government's Exemption 5 withholdings cannot survive because BOP has failed to meet
rehensive guidance as to how a BOP staff member should respond to an inmate's suicide attempt. See U.S. Dep't of Justice Nat'l Inst. of Corrections, National Study ofJail Suicide: 20 Years Later (Apr. 2010), at 52, https://bitly/31YuolCm (discussing the three requisite 9 EFTA00071621 Case 1:20-cv-00833-PAE
ption 5, the deliberative process privilege "does not operate indiscriminately to shield all decision-making by public officials." N.Y. Times Co. v. Dep't of Def., 499 F. Supp. 2d 501, 514 (S.D.N.Y. 2007). Moreover, the Government's Exemption 5 withholdings cannot survive because BOP has failed to meet
rehensive guidance as to how a BOP staff member should respond to an inmate's suicide attempt. See U.S. Dep't of Justice Nat'l Inst. of Corrections, National Study ofJail Suicide: 20 Years Later (Apr. 2010), at 52, https://bitly/31YuolCm (discussing the three requisite 9 EFTA00088572 Case 1:20-cv-00833-PAE
Entities connected to both Dep't and National Study

Jeffrey Epstein
PERSON
Julie K. Brown
PERSON
Andrew Cuomo
PERSON
Alberto Gonzales
PERSONShapiro
PERSON
The New York Times
ORGANIZATION
Human Rights Watch
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATIOND.C. Cir
ORGANIZATIONHomeland Sec
ORGANIZATIONRadcliffe
PERSONTimothy Dalton Vaughn
PERSONChristina Goldbaum
PERSONFederal Bureau of Prisons
ORGANIZATIONNicholas Tartaglione
PERSONAli Watkins
PERSONAl-Amyn Sumar
PERSONN.Y. Times Co.
ORGANIZATIONSuicide
PERSONe.g„ Christenson Decl
PERSON