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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-
riminately 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 the "foreseeable harm" standard created by the FOIA Improvement Act of 2016. In its 8 E
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-
riminately 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 the "foreseeable harm" standard created by the FOIA Improvement Act of 2016. In its 8 E
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-
riminately 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 the "foreseeable harm" standard created by the FOIA Improvement Act of 2016. In its 8 E
Entities connected to both THE NEW YORK TIMES COMPANY and the Government's Exemption 5

Jeffrey Epstein
PERSON
Metropolitan Correctional Center
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATIONNicholas Tartaglione
PERSON
Human Rights Watch
ORGANIZATIOND.C. Cir
ORGANIZATIONRadcliffe
PERSONDavid E. McCraw
PERSON
The New York Times
ORGANIZATIONHomeland Sec
ORGANIZATION
Andrew Cuomo
PERSON
Alberto Gonzales
PERSONRussell Capone
PERSONKara Christenson
PERSONShapiro
PERSONU.S. Dept of Commerce
ORGANIZATIONTimothy Dalton Vaughn
PERSON
Julie K. Brown
PERSONChristina Goldbaum
PERSONAli Watkins
PERSON