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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-
ocedures discussing the specific duties of the officers on duty at the time of suicide events and the equipment needed by those staff members. U.S. Dep't of Justice Nat'l Inst. of Corrections, Prison Suicide: An Overview and Guide to Prevention (1995), at 23-25, https://bit.ly/2FhaZnb. There is nothing s
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-
ocedures discussing the specific duties of the officers on duty at the time of suicide events and the equipment needed by those staff members. U.S. Dep't of Justice Nat'l Inst. of Corrections, Prison Suicide: An Overview and Guide to Prevention (1995), at 23-25, https://bit.ly/2FhaZnb. There is nothing s
Case 1:20-cv-00833-PAE Document 27 Filed 09/10/20 Page 1 of 29 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 MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR S
Y. Times (Aug. 19, 2019) 16 U.S. Dep't of Justice Nat'l Inst. of Corrections, National Study of Jail Suicide: 20 Years Later (Apr. 2010) 22 U.S. Dep't of Justice Nat'l Inst. of Corrections, Prison Suicide: An Overview and Guide to Prevention (1995) 21, 22 World Health Organization, Preventing Suicid
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-
ocedures discussing the specific duties of the officers on duty at the time of suicide events and the equipment needed by those staff members. U.S. Dep't of Justice Nat'l Inst. of Corrections, Prison Suicide: An Overview and Guide to Prevention (1995), at 23-25, https://bit.ly/2FhaZnb. There is nothing s
Case 1:20-cv-00833-PAE Document 27 Filed 09/10/20 Page 1 of 29 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 MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR S
Y. Times (Aug. 19, 2019) 16 U.S. Dep't of Justice Nat'l Inst. of Corrections, National Study of Jail Suicide: 20 Years Later (Apr. 2010) 22 U.S. Dep't of Justice Nat'l Inst. of Corrections, Prison Suicide: An Overview and Guide to Prevention (1995) 21, 22 World Health Organization, Preventing Suicid
Entities connected to both THE NEW YORK TIMES COMPANY and Dep't of

Jeffrey Epstein
PERSON
Metropolitan Correctional Center
ORGANIZATIONNicholas Tartaglione
PERSONFederal Bureau of Prisons
ORGANIZATIONSpecial Housing Unit
ORGANIZATIONRadcliffe
PERSOND.C. Cir
ORGANIZATION
Human Rights Watch
ORGANIZATIONDavid E. McCraw
PERSONTova Noel
PERSON
Alberto Gonzales
PERSONRussell Capone
PERSON
Andrew Cuomo
PERSON
The New York Times
ORGANIZATIONHomeland Sec
ORGANIZATION
United States
LOCATION
Hopkins
ORGANIZATIONU.S. Citizenship & Immigration Servs
ORGANIZATIONFavish
PERSON
Doherty
PERSON