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Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, COMPLAINT - against - FEDERAL BUREAU OF PRISONS, Defendant. X Plaintiff THE NEW YORK TIMES COMPANY ("The Times"), by its undersi
ries showing which cells Epstein was housed in at MCC; incident reports related to Epstein at MCC; the Central Inmate Monitoring (CIM) Clearance and Separatee data sheet for Epstein at MCC; security designation records and chronological disciplinary records for Epstein at MCC; and the signed visitor log f
Case 1:20-cv-00833-PAE Document 23 Filed 08/05/20 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK THE NEW YORK TIMES COMPANY, Plaintiff, v. FEDERAL BUREAU OF PRISONS, Defendant. 20-CV-00833 (PAE) DECLARATION OF NICOLE MCFARLAND I, Nicole McFarland, declare as follows
cell or part of the facility he was housed in. 10. CIM CLEARANCE SHEET/SEPARATEE DATA — With respect to Plaintiff's request for "CIM Clearance and Separatee data sheet for Jeffrey Epstein at MCC[,]" Central Office conducted a search of the SENTRY database, as described in the Christenson Declaration. Th
Case 1:20-cv-00833-PAE Document 23 Filed 08/05/20 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK THE NEW YORK TIMES COMPANY, Plaintiff, v. FEDERAL BUREAU OF PRISONS. Defendant. eclare as follows: 20-CV-00833 (PAE) 1. I am employed by the United States Department of
cell or part of the facility he was housed in. 10. CIM CLEARANCE SHEET/SEPARATEE DATA — With respect to Plaintiff's request for "CIM Clearance and Separatee data sheet for Jeffrey Epstein at MCC[,]" Central Office conducted a search of the SENTRY database, as described in the Christenson Declaration. Th
Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, COMPLAINT - against - FEDERAL BUREAU OF PRISONS, Defendant. X Plaintiff THE NEW YORK TIMES COMPANY ("The Times"), by its undersi
ries showing which cells Epstein was housed in at MCC; incident reports related to Epstein at MCC; the Central Inmate Monitoring (CIM) Clearance and Separatee data sheet for Epstein at MCC; security designation records and chronological disciplinary records for Epstein at MCC; and the signed visitor log f
Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, COMPLAINT - against - FEDERAL BUREAU OF PRISONS, Defendant. X Plaintiff THE NEW YORK TIMES COMPANY ("The Times"), by its undersi
ries showing which cells Epstein was housed in at MCC; incident reports related to Epstein at MCC; the Central Inmate Monitoring (CIM) Clearance and Separatee data sheet for Epstein at MCC; security designation records and chronological disciplinary records for Epstein at MCC; and the signed visitor log f
Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, COMPLAINT - against - FEDERAL BUREAU OF PRISONS, Defendant. X Plaintiff THE NEW YORK TIMES COMPANY ("The Times"), by its undersi
ries showing which cells Epstein was housed in at MCC; incident reports related to Epstein at MCC; the Central Inmate Monitoring (CIM) Clearance and Separatee data sheet for Epstein at MCC; security designation records and chronological disciplinary records for Epstein at MCC; and the signed visitor log f
Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X THE NEW YORK TIMES COMPANY, Plaintiff, COMPLAINT - against - FEDERAL BUREAU OF PRISONS, Defendant. X Plaintiff THE NEW YORK TIMES COMPANY ("The Times"), by its undersi
ries showing which cells Epstein was housed in at MCC; incident reports related to Epstein at MCC; the Central Inmate Monitoring (CIM) Clearance and Separatee data sheet for Epstein at MCC; security designation records and chronological disciplinary records for Epstein at MCC; and the signed visitor log f
Entities connected to both THE NEW YORK TIMES COMPANY and Separatee

Jeffrey Epstein
PERSON
Metropolitan Correctional Center
ORGANIZATIONSpecial Housing Unit
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATIONDavid E. McCraw
PERSONCorrlinks
ORGANIZATIONChristenson
PERSONAlexandra Perloff-Giles
PERSONthe Central Inmate Monitoring
ORGANIZATION
FedEx
ORGANIZATIONFOIA/PA
ORGANIZATIONKara Christenson
PERSON
United States Department of Justice
ORGANIZATIONTRULINKS
ORGANIZATIONthe DROP File for Epstein
ORGANIZATIONthe Inspector General
ORGANIZATIONthe MCC Warden
ORGANIZATIONthe Roster/Overtime Program
ORGANIZATIONBOP's Central Office
ORGANIZATIONMCC Warden
ORGANIZATION