Epstein Secrets

Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK • THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. X 20 Civ. 833 (PAE) REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE FEDERAL BUREAU OF

emonstrate a "rational link" between the requested public disclosure and interference with ongoing or prospective investigations or proceedings. See Crooker v. Bureau of 4 Through counsel, plaintiff has also agreed not to challenge the application of Exemptions 7(E) and 7(F) to such information in records withhel

Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK • THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. X 20 Civ. 833 (PAE) REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE FEDERAL BUREAU OF

emonstrate a "rational link" between the requested public disclosure and interference with ongoing or prospective investigations or proceedings. See Crooker v. Bureau of 4 Through counsel, plaintiff has also agreed not to challenge the application of Exemptions 7(E) and 7(F) to such information in records withhel

Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK THE NEW YORK TIMES COMPANY, Plaintiff, -v- FEDERAL BUREAU OF PRISONS, Defendant. X 20 Civ. 833 (PAE) REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE FEDERAL BUREAU OF

emonstrate a "rational link" between the requested public disclosure and interference with ongoing or prospective investigations or proceedings. See Crooker v. Bureau of Through counsel, plaintiff has also agreed not to challenge the application of Exemptions 7(E) and 7(F) to such information in records withheld