Epstein Secrets

Case 1:20-cv-00833-PAE Document 42 Filed 02/10/21 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, No. 20-cv-00833 (PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. X REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFF'S CROSS-

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

Case 1:20-cv-00833-PAE Document 42 Filed 02/10/21 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, No. 20-cv-00833 (PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. X REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFF'S CROSS-

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

Case 1:20-cv-00833-PAE Document 42 Filed 02/10/21 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, No. 20-cv-00833 (PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. X REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFF'S CROSS-

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