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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
D.N.Y. 2002). The agency must demonstrate that its search was "reasonably calculated to discover the requested documents." SafeCard Servs., Inc. v. S.E. C., 926 F.2d 1197, 328 (D.C. Cir. 1991). An agency's search may be reasonable even if it does not return every responsive document. See Adamowicz v. I
2 mentions1 same-page
Page ?Same page
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
D.N.Y. 2002). The agency must demonstrate that its search was "reasonably calculated to discover the requested documents." SafeCard Servs., Inc. v. S.E. C., 926 F.2d 1197, 328 (D.C. Cir. 1991). An agency's search may be reasonable even if it does not return every responsive document. See Adamowicz v. I
2 mentions1 same-page
Page ?Same page
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
D.N.Y. 2002). The agency must demonstrate that its search was "reasonably calculated to discover the requested documents." SafeCard Servs., Inc. v. S.E. C., 926 F.2d 1197, 328 (D.C. Cir. 1991). An agency's search may be reasonable even if it does not return every responsive document. See Adamowicz v. I
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Entities connected to both THE NEW YORK TIMES COMPANY and S.E. C.
Jeffrey Epstein
PERSON29 w/ THE·3 w/ S.E.
Metropolitan Correctional Center
ORGANIZATION20 w/ THE·3 w/ S.E.
NT
Nicholas Tartaglione
PERSON17 w/ THE·3 w/ S.E.
Special Housing Unit
ORGANIZATION17 w/ THE·3 w/ S.E.
the Southern District
LOCATION12 w/ THE·3 w/ S.E.
TN
Tova Noel
PERSON11 w/ THE·3 w/ S.E.
D.C. Cir
ORGANIZATION11 w/ THE·3 w/ S.E.
RA
Radcliffe
PERSON11 w/ THE·3 w/ S.E.
the Acting United States
ORGANIZATION11 w/ THE·3 w/ S.E.
Human Rights Watch
ORGANIZATION11 w/ THE·3 w/ S.E.
CH
Christenson
PERSON10 w/ THE·3 w/ S.E.
Homeland Sec
ORGANIZATION9 w/ THE·3 w/ S.E.
The New York Times
ORGANIZATION9 w/ THE·3 w/ S.E.
RC
Russell Capone
PERSON9 w/ THE·3 w/ S.E.
Alberto Gonzales
PERSON8 w/ THE·3 w/ S.E.
Judicial Watch, Inc.
ORGANIZATION8 w/ THE·3 w/ S.E.
the Tenth Circuit's
ORGANIZATION8 w/ THE·3 w/ S.E.
MT
Michael Thomas
PERSON8 w/ THE·3 w/ S.E.
Doherty
PERSON8 w/ THE·3 w/ S.E.
United States
LOCATION8 w/ THE·3 w/ S.E.