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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-
anding of the operations or activities of the government," insofar as they would provide the public with greater information about how Epstein died. Dep't of Def. v. FLRA, 510 U.S. 487, 495 (1994). Moreover, there is a significant amount of "media coverage of speculation and theories about Epstein's death."
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-
anding of the operations or activities of the government," insofar as they would provide the public with greater information about how Epstein died. Dep't of Def. v. FLRA, 510 U.S. 487, 495 (1994). Moreover, there is a significant amount of "media coverage of speculation and theories about Epstein's death."
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-
anding of the operations or activities of the government," insofar as they would provide the public with greater information about how Epstein died. Dep't of Def. v. FLRA, 510 U.S. 487, 495 (1994). Moreover, there is a significant amount of "media coverage of speculation and theories about Epstein's death."
Entities connected to both THE NEW YORK TIMES COMPANY and Dep't of Def

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