Epstein Secrets

Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK • THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. X 20 Civ. 833 (PAE) REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE FEDERAL BUREAU OF

Housing Unit, sources typically relied upon and information-gathering steps taken in investigating incidents at the MCC, details about how BOP After Action Review teams conduct their work, and information about where evidence is stored. See Supp. Christenson Decl. q¶ 18- 25; see also, e.g., Human Rights Watch,

Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK • THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. X 20 Civ. 833 (PAE) REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE FEDERAL BUREAU OF

Housing Unit, sources typically relied upon and information-gathering steps taken in investigating incidents at the MCC, details about how BOP After Action Review teams conduct their work, and information about where evidence is stored. See Supp. Christenson Decl. q¶ 18- 25; see also, e.g., Human Rights Watch,

Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. X 20 Civ. 833 (PAE) REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE FEDERAL BUREAU OF

Housing Unit, sources typically relied upon and information-gathering steps taken in investigating incidents at the MCC, details about how BOP After Action Review teams conduct their work, and information about where evidence is stored. See Supp. Decl. 11118- 25; see also, e.g., Human Rights Watch, 2015 WL 54