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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-
nforcement purposes" because they were created "in the exercise of BOP's statutory authority to detain arrested individuals." (Supplemental Decl. of Kara Christenson, ECF No. 39 [hereinafter "Christenson Supp. Decl."], at ¶ 29.) But this sweeping application of Exemption 7(A) would effectively shield every BOP r
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-
nforcement purposes" because they were created "in the exercise of BOP's statutory authority to detain arrested individuals." (Supplemental Decl. of Kara Christenson, ECF No. 39 [hereinafter "Christenson Supp. Decl."], at ¶ 29.) But this sweeping application of Exemption 7(A) would effectively shield every BOP r
Case 1:20-cv-00833-PAE Document 23 Filed 08/05/20 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK THE NEW YORK TIMES COMPANY, Plaintiff, v. FEDERAL BUREAU OF PRISONS, Defendant. 20-CV-00833 (PAE) DECLARATION OF NICOLE MCFARLAND I, Nicole McFarland, declare as follows
ents. In this capacity, I typically work with staff at BOP's Central Office. In this case, I communicated with BOP Government Information Specialist Kara Christenson regarding Plaintiff's FOIA requests. 3. I submit this declaration in support of the BOP's motion for summary judgment and to 1 EFTA00075372 Cas
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK THE NEW YORK TIMES COMPANY. Plaintiff, No. 20-CV-833(PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. SUPPLEMENTAL DECLARATION OF hereby declare as follows: I. I am Couns
ed Records"), including those reflected as withheld in full at Entries 55- 57 and 60 on the updated index attached to the Supplemental Declaration of Kara Christenson (the "updated BOP index"). The 7(A) Returned Records fall into four categories: documents related to counts of inmates, staffing records, psycholog
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-
nforcement purposes" because they were created "in the exercise of BOP's statutory authority to detain arrested individuals." (Supplemental Decl. of Kara Christenson, ECF No. 39 [hereinafter "Christenson Supp. Decl."], at ¶ 29.) But this sweeping application of Exemption 7(A) would effectively shield every BOP r
Case 1:20-cv-00833-PAE Document 23 Filed 08/05/20 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK THE NEW YORK TIMES COMPANY, Plaintiff, v. FEDERAL BUREAU OF PRISONS. Defendant. eclare as follows: 20-CV-00833 (PAE) 1. I am employed by the United States Department of
ents. In this capacity, I typically work with staff at BOP's Central Office. In this case, I communicated with BOP Government Information Specialist Kara Christenson regarding Plaintiff's FOIA requests. 3. I submit this declaration in support of the BOP's motion for summary judgment and to 1 EFTA00088661 Cas
Case 1:20-cv-00833-PAE Document 40 Filed 01/15/21 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK THE NEW YORK TIMES COMPANY. Plaintiff, No. 20-CV-833(PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. reby declare as follows: I. I am Counsel to the Acting United States
ed Records"), including those reflected as withheld in full at Entries 55- 57 and 60 on the updated index attached to the Supplemental Declaration of Kara Christenson (the "updated BOP index"). The 7(A) Returned Records fall into four categories: documents related to counts of inmates, staffing records, psycholog
Entities connected to both THE NEW YORK TIMES COMPANY and Kara Christenson

Jeffrey Epstein
PERSON
Metropolitan Correctional Center
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATIONNicholas Tartaglione
PERSONSpecial Housing Unit
ORGANIZATIONthe Southern District
LOCATIONRadcliffe
PERSON
Human Rights Watch
ORGANIZATIOND.C. Cir
ORGANIZATIONthe Acting United States
ORGANIZATIONDavid E. McCraw
PERSON
The New York Times
ORGANIZATIONChristenson
PERSONHomeland Sec
ORGANIZATION
Alberto Gonzales
PERSON
Andrew Cuomo
PERSONRussell Capone
PERSONSeparatee
ORGANIZATIONShapiro
PERSONU.S. Dept of Commerce
ORGANIZATION