Epstein Secrets

tuart, 427 U.S. 539, 565 (1976)). Nor is withholding the records the only measure that courts can use to mitigate the adverse effects of publicity. Neb. Press Ass 'n, 427 U.S. at 563-64 (enumerating methods to mitigate the effect of pre- trial publicity including: "change of [a trial] venue," "postponement of the

3 (PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. X REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT David E. McCraw Al-Amyn Sumar Alexandra Settelmayer The New York Times Company Legal Department 620 Eighth Avenue New York, NY 10018 Phone: 212-556-4031 Facs

tuart, 427 U.S. 539, 565 (1976)). Nor is withholding the records the only measure that courts can use to mitigate the adverse effects of publicity. Neb. Press Ass 'n, 427 U.S. at 563-64 (enumerating methods to mitigate the effect of pre- trial publicity including: "change of [a trial] venue," "postponement of the

3 (PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. X REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT David E. McCraw Al-Amyn Sumar Alexandra Settelmayer The New York Times Company Legal Department 620 Eighth Avenue New York, NY 10018 Counsel for Plaintiff EF

tuart, 427 U.S. 539, 565 (1976)). Nor is withholding the records the only measure that courts can use to mitigate the adverse effects of publicity. Neb. Press Ass 'n, 427 U.S. at 563-64 (enumerating methods to mitigate the effect of pre- trial publicity including: "change of [a trial] venue," "postponement of the

3 (PAE) v. FEDERAL BUREAU OF PRISONS, Defendant. X REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT David E. McCraw Al-Amyn Sumar Alexandra Settelmayer The New York Times Company Legal Department 620 Eighth Avenue New York, NY 10018 Counsel for Plaintiff EF