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Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 1 of 30 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. 20 Civ. 833 (PAE) MEMORANDUM OF LAW IN SUPPORT OF THE FEDERAL BUREAU OF PRISONS'S MOTION
. Declaration of Russell Capone, Counsel to the Acting United States Attorney for the Southern District of New York ("Capone Declaration") ¶ 4; see Docket Entry dated July 8, 2019, United States v. Epstein, No. 19-cr-490 (RMB) (S.D.N.Y.). On July 23, 2019, Epstein apparently attempted suicide in his cell at
Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 1 of 30 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. 20 Civ. 833 (PAE) MEMORANDUM OF LAW IN SUPPORT OF THE FEDERAL BUREAU OF PRISONS'S MOTION
. Declaration of Russell Capone, Counsel to the Acting United States Attorney for the Southern District of New York ("Capone Declaration") ¶ 4; see Docket Entry dated July 8, 2019, United States v. Epstein, No. 19-cr-490 (RMB) (S.D.N.Y.). On July 23, 2019, Epstein apparently attempted suicide in his cell at
Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 1 of 30 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff; -v- FEDERAL BUREAU OF PRISONS, Defendant. 20 Civ. 833 (PAE) MEMORANDUM OF LAW IN SUPPORT OF THE FEDERAL BUREAU OF PRISONS'S MOTION
. Declaration of Russell Capone, Counsel to the Acting United States Attorney for the Southern District of New York ("Capone Declaration") ¶ 4; see Docket Entry dated July 8, 2019, United States v. Epstein, No. 19-cr-490 (RMB) (S.D.N.Y.). On July 23, 2019, Epstein apparently attempted suicide in his cell at
Entities connected to both THE NEW YORK TIMES COMPANY and Docket Entry

Jeffrey Epstein
PERSON
Metropolitan Correctional Center
ORGANIZATION
United States
LOCATIONSpecial Housing Unit
ORGANIZATIONthe Southern District
LOCATIONNicholas Tartaglione
PERSON
Human Rights Watch
ORGANIZATIONRadcliffe
PERSONTova Noel
PERSONthe Acting United States
ORGANIZATIOND.C. Cir
ORGANIZATION
George W. Bush
PERSON
The New York Times
ORGANIZATION
Department of Justice
ORGANIZATIONChristenson
PERSONHomeland Sec
ORGANIZATION
Alberto Gonzales
PERSON
Supreme Court
ORGANIZATION
Andrew Cuomo
PERSON
Doherty
PERSON