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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
92), but lbJecause the DOJ is an agency specializing in law enforcement, its claim of a law enforcement purpose is entitled to deference," Ctr. for Nat'l Sec. Studies v. U.S. Dep't of Justice,331 F.3d 918, 926 Exemption 7(A) also protects records that, if released, could interfere with post-trial criminal
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
92), but lbJecause the DOJ is an agency specializing in law enforcement, its claim of a law enforcement purpose is entitled to deference," Ctr. for Nat'l Sec. Studies v. U.S. Dep't of Justice,331 F.3d 918, 926 Exemption 7(A) also protects records that, if released, could interfere with post-trial criminal
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
92), but lbJecause the DOJ is an agency specializing in law enforcement, its claim of a law enforcement purpose is entitled to deference," Ctr. for Nat'l Sec. Studies v. U.S. Dep't of Justice,331 F.3d 918, 926 Exemption 7(A) also protects records that, if released, could interfere with post-trial criminal
Entities connected to both THE NEW YORK TIMES COMPANY and Nat'l Sec

Jeffrey Epstein
PERSON
Metropolitan Correctional Center
ORGANIZATIONSpecial Housing Unit
ORGANIZATIONNicholas Tartaglione
PERSONthe Southern District
LOCATIONTova Noel
PERSONRadcliffe
PERSONthe Acting United States
ORGANIZATIOND.C. Cir
ORGANIZATION
Human Rights Watch
ORGANIZATIONChristenson
PERSONRussell Capone
PERSONJudicial Watch, Inc.
ORGANIZATION
United States
LOCATIONHomeland Sec
ORGANIZATION
The New York Times
ORGANIZATION
Andrew Cuomo
PERSONthe Tenth Circuit's
ORGANIZATIONMichael Thomas
PERSON
Alberto Gonzales
PERSON