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4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x THE NEW YORK TIMES COMPANY, Plaintiff, v. 20 CV 833 (PAE) Remote Conference FEDERAL BUREAU OF PRISONS, Defendant. Before: x New York, N.Y. April 9, 2021 4:00 p.m. H
d from a false reports case. I think, second, documents that appear to be assignment rosters and so forth, which you see on the first page of the Vaughn Index, again, it's not clear how those connect. Maybe they can — I think we've heard a couple of theories of possibly getting there — but we'd like
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-
eland Sec., 852 F. Supp. 2d 66, 80 (D.D.C. 2012) ("Where an agency has publicly disclosed information that is similar to what is being withheld, its Vaughn submission must be `sufficiently detailed' to distinguish the withheld information from the public information."). CONCLUSION For the foregoing re
4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x THE NEW YORK TIMES COMPANY, Plaintiff, v. 20 CV 833 (PAE) Remote Conference FEDERAL BUREAU OF PRISONS, Defendant. Before: x New York, N.Y. April 9, 2021 4:00 p.m. H
d from a false reports case. I think, second, documents that appear to be assignment rosters and so forth, which you see on the first page of the Vaughn Index, again, it's not clear how those connect. Maybe they can — I think we've heard a couple of theories of possibly getting there — but we'd like
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-
eland Sec., 852 F. Supp. 2d 66, 80 (D.D.C. 2012) ("Where an agency has publicly disclosed information that is similar to what is being withheld, its Vaughn submission must be `sufficiently detailed' to distinguish the withheld information from the public information."). CONCLUSION For the foregoing re
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-
eland Sec., 852 F. Supp. 2d 66, 80 (D.D.C. 2012) ("Where an agency has publicly disclosed information that is similar to what is being withheld, its Vaughn submission must be `sufficiently detailed' to distinguish the withheld information from the public information."). CONCLUSION For the foregoing re
Entities connected to both THE NEW YORK TIMES COMPANY and Timothy Dalton Vaughn

Jeffrey Epstein
PERSON
Metropolitan Correctional Center
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATIONNicholas Tartaglione
PERSONthe Southern District
LOCATION
Julie K. Brown
PERSON
United States
LOCATION
Andrew Cuomo
PERSONRadcliffe
PERSON
Human Rights Watch
ORGANIZATIOND.C. Cir
ORGANIZATION
Alberto Gonzales
PERSON
Supreme Court
ORGANIZATIONTova Noel
PERSONDavid E. McCraw
PERSONShapiro
PERSON
The New York Times
ORGANIZATIONHomeland Sec
ORGANIZATION
Department of Justice
ORGANIZATION
Audrey Strauss
PERSON