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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
anding of the operations or activities of the government," insofar as they would provide the public with greater information about how Epstein died. Dep't of Def. v. FLRA, 510 U.S. 487, 495 (1994). Moreover, there is a significant amount of "media coverage of speculation and theories about Epstein's death."
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
anding of the operations or activities of the government," insofar as they would provide the public with greater information about how Epstein died. Dep't of Def. v. FLRA, 510 U.S. 487, 495 (1994). Moreover, there is a significant amount of "media coverage of speculation and theories about Epstein's death."
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
anding of the operations or activities of the government," insofar as they would provide the public with greater information about how Epstein died. Dep't of Def. v. FLRA, 510 U.S. 487, 495 (1994). Moreover, there is a significant amount of "media coverage of speculation and theories about Epstein's death."
Entities connected to both David E. McCraw and Dep't of Def

THE NEW YORK TIMES COMPANY
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
Jeffrey Epstein
PERSON
Andrew Cuomo
PERSON
Julie K. Brown
PERSON
Alberto Gonzales
PERSON
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