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

re expected to testify, and information and documents prepared by potential trial witnesses. See Supplemental Declaration of Russell Capone ("Supp. Capone Decl.") ¶¶ 6-14. In addition, information contained in two of the withheld Returned Records relates to the circumstances of Epstein's apparent suicide at

Case 1:20-cv-00833-PAE Document 27 Filed 09/10/20 Page 1 of 29 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 MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR S

f 18 U.S.C. § 371, and one count of sex trafficking, in violation of 18 U.S.C. § 1591. (See Declaration of Russell Capone, ECF No. 22 [hereinafter "Capone Decl."], at ¶ 4.) On July 6, 2019, he was arrested and charged by federal prosecutors and thereafter incarcerated at the MCC. (Id.) On July 10, 2019, Eps

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

re expected to testify, and information and documents prepared by potential trial witnesses. See Supplemental Declaration of Russell Capone ("Supp. Capone Decl.") ¶¶ 6-14. In addition, information contained in two of the withheld Returned Records relates to the circumstances of Epstein's apparent suicide at

Case 1:20-cv-00833-PAE Document 27 Filed 09/10/20 Page 1 of 29 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 MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR S

f 18 U.S.C. § 371, and one count of sex trafficking, in violation of 18 U.S.C. § 1591. (See Declaration of Russell Capone, ECF No. 22 [hereinafter "Capone Decl."], at ¶ 4.) On July 6, 2019, he was arrested and charged by federal prosecutors and thereafter incarcerated at the MCC. (Id.) On July 10, 2019, Eps