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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
criminal proceedings. Plaintiff's argument that disclosure pursuant to a protective order would foreclose any possible interference with Noel, see P. MOL at 13, incorrectly conflates disclosure to criminal defendants pursuant to a protective order with public disclosure under FOIA. The Capone Declara
2 mentions1 same-page
Page ?Same page
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
criminal proceedings. Plaintiff's argument that disclosure pursuant to a protective order would foreclose any possible interference with Noel, see P. MOL at 13, incorrectly conflates disclosure to criminal defendants pursuant to a protective order with public disclosure under FOIA. The Capone Declara
2 mentions1 same-page
Page ?Same page
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
criminal proceedings. Plaintiff's argument that disclosure pursuant to a protective order would foreclose any possible interference with Noel, see P. MOL at 13, incorrectly conflates disclosure to criminal defendants pursuant to a protective order with public disclosure under FOIA. The Declarations e
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Entities connected to both THE NEW YORK TIMES COMPANY and P. MOL
Jeffrey Epstein
PERSON29 w/ THE·3 w/ P.
Federal Bureau of Prisons
ORGANIZATION18 w/ THE·3 w/ P.
NT
Nicholas Tartaglione
PERSON17 w/ THE·3 w/ P.
the Southern District
LOCATION12 w/ THE·3 w/ P.
TN
Tova Noel
PERSON11 w/ THE·3 w/ P.
D.C. Cir
ORGANIZATION11 w/ THE·3 w/ P.
Human Rights Watch
ORGANIZATION11 w/ THE·3 w/ P.
RA
Radcliffe
PERSON11 w/ THE·3 w/ P.
the Acting United States
ORGANIZATION11 w/ THE·3 w/ P.
CH
Christenson
PERSON10 w/ THE·2 w/ P.
The New York Times
ORGANIZATION9 w/ THE·3 w/ P.
Homeland Sec
ORGANIZATION9 w/ THE·3 w/ P.
United States
LOCATION8 w/ THE·3 w/ P.
Doherty
PERSON8 w/ THE·3 w/ P.
Audrey Strauss
PERSON8 w/ THE·3 w/ P.
Robbins Tire & Rubber Co.
ORGANIZATION8 w/ THE·3 w/ P.
FA
Favish
PERSON8 w/ THE·3 w/ P.
the Tenth Circuit's
ORGANIZATION8 w/ THE·3 w/ P.
Hopkins
ORGANIZATION8 w/ THE·3 w/ P.
Judicial Watch, Inc.
ORGANIZATION8 w/ THE·3 w/ P.