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riminately to shield all decision-making by public officials." N.Y. Times Co. v. Dep't of Def., 499 F. Supp. 2d 501, 514 (S.D.N.Y. 2007). Moreover, the Government's Exemption 5 withholdings cannot survive because BOP has failed to meet the "foreseeable harm" standard created by the FOIA Improvement Act of 2016. In its 8 E
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
riminately to shield all decision-making by public officials." N.Y. Times Co. v. Dep't of Def., 499 F. Supp. 2d 501, 514 (S.D.N.Y. 2007). Moreover, the Government's Exemption 5 withholdings cannot survive because BOP has failed to meet the "foreseeable harm" standard created by the FOIA Improvement Act of 2016. In its 8 E
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
riminately to shield all decision-making by public officials." N.Y. Times Co. v. Dep't of Def., 499 F. Supp. 2d 501, 514 (S.D.N.Y. 2007). Moreover, the Government's Exemption 5 withholdings cannot survive because BOP has failed to meet the "foreseeable harm" standard created by the FOIA Improvement Act of 2016. In its 8 E
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
Entities connected to both the Government's Exemption 5 and David E. McCraw

THE NEW YORK TIMES COMPANY
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
Jeffrey Epstein
PERSON
Andrew Cuomo
PERSON
Julie K. Brown
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Alberto Gonzales
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Human Rights Watch
ORGANIZATIONChristina Goldbaum
PERSONNicholas Tartaglione
PERSONAli Watkins
PERSONAl-Amyn Sumar
PERSONSuicide
PERSOND.C. Cir
ORGANIZATIONMichael Gold
PERSONU.S. Citizenship & Immigration Servs
ORGANIZATIONNational Study of Jail
ORGANIZATIONJustice Nat'l Inst
ORGANIZATIONDep't of
ORGANIZATIONRadcliffe
PERSONDep't
ORGANIZATION