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equest Seeking Photos Of Jeffrey Epstein And Records Surrounding His Apparent Suicide (Aug. 12, 2019) 8 Nick Bryant, Here Is Pedophile Billionaire Jeffrey Epstein's Little Black Book, Gawker (Jan. 23, 2015) 16 Office of the Inspector General, Audit of the Federal Bureau of Prisons ' Monitoring of Inmate Commu
rtment of Justice's Inspector General, and the Bureau of Prisons itself all launched investigations. For his part, the President has suggested that Epstein was "killed" while in federal custody. Matt Zapotosky, Trump questions whether Jeffrey Epstein was killed in federal custody. His attorney general a
ive is his brother Mark, who has said they "were not that close" and is himself eager for more documents to be released by BOP. See Julie K. Brown, Je •ey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself Brother Says, Miami Herald (Nov. 14, 2019), hups://hrld.us/3ibIANJ (noting that "Mark Epstein
m OTHER AUTHORITIES Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in
s to be released by BOP. See Julie K. Brown, Je •ey Epstein Wasn't Trafficking Women — And He Didn't Kill Hi
ORT OF PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT AND IN OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT David E. McCraw Al-Amyn Sumar Alexandra Perloff-Giles The New York Times Company Legal Department Counsel for Plaintiff EFTA00071624 Case 1:20-cv-00833-PAE Document 27 Filed 09/10/20 Page 2 of 29
m OTHER AUTHORITIES Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in
s to be released by BOP. See Julie K. Brown, Je •ey Epstein Wasn't Trafficking Women — And He Didn't Kill Hi
equest Seeking Photos Of Jeffrey Epstein And Records Surrounding His Apparent Suicide (Aug. 12, 2019) 8 Nick Bryant, Here Is Pedophile Billionaire Jeffrey Epstein's Little Black Book, Gawker (Jan. 23, 2015) 16 Office of the Inspector General, Audit of the Federal Bureau of Prisons ' Monitoring of Inmate Commu
rtment of Justice's Inspector General, and the Bureau of Prisons itself all launched investigations. For his part, the President has suggested that Epstein was "killed" while in federal custody. Matt Zapotosky, Trump questions whether Jeffrey Epstein was killed in federal custody. His attorney general a
ive is his brother Mark, who has said they "were not that close" and is himself eager for more documents to be released by BOP. See Julie K. Brown, Je •ey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself Brother Says, Miami Herald (Nov. 14, 2019), hups://hrld.us/3ibIANJ (noting that "Mark Epstein
ORT OF PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT AND IN OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT David E. McCraw Al-Amyn Sumar Alexandra Perloff-Giles The New York Times Company Legal Department 620 Eighth Avenue New York, NY 10018 Phone: 212-556-4031 Facsimile: (212) 556-4634 Email: mccraw@n
that request centered on records relating to the designation of Epstein as a suicide risk: "Documents showing when MCC staff held meetings regarding Jeffrey Epstein, and who attended"; "All records generated from the meeting at MCC during which it was decided that Jeffrey Epstein would be taken off suicide watch
Epstein, the wealthy financier charged with sex trafficking of minors who died at the Metropolitan Correctional Center ("MCC") on August 10, 2019. Epstein's relationships with prominent figures in politics, business, and Hollywood entertainment contribute to the public interest in Epstein and the circu
perly made by Plaintiff. 2. The records concern Jeffrey Epstein, the wealthy financier charged with sex
to BOP. The request sought: "(1) The full log of Mr. Epstein's phone calls to and from the MCC"; "(2) All ema
uch other and further relief as this Court deems just and proper. Dated: New York, New York January 30, 2020 /s/ David E. McCraw David E. McCraw Alexandra Perloff-Giles 6 EFTA00074145 Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 7 of 7 Legal Department The New York Times Company 620 8th Avenue New Yo
that request centered on records relating to the designation of Epstein as a suicide risk: "Documents showing when MCC staff held meetings regarding Jeffrey Epstein, and who attended"; "All records generated from the meeting at MCC during which it was decided that Jeffrey Epstein would be taken off suicide watch
Epstein, the wealthy financier charged with sex trafficking of minors who died at the Metropolitan Correctional Center ("MCC") on August 10, 2019. Epstein's relationships with prominent figures in politics, business, and Hollywood entertainment contribute to the public interest in Epstein and the circu
perly made by Plaintiff. 2. The records concern Jeffrey Epstein, the wealthy financier charged with sex
to BOP. The request sought: "(1) The full log of Mr. Epstein's phone calls to and from the MCC"; "(2) All ema
uch other and further relief as this Court deems just and proper. Dated: New York, New York January 30, 2020 /s/ David E. McCraw David E. McCraw Alexandra Perloff-Giles 6 EFTA00091291 Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 7 of 7 Legal Department The New York Times Company 620 8th Avenue New Yo
that request centered on records relating to the designation of Epstein as a suicide risk: "Documents showing when MCC staff held meetings regarding Jeffrey Epstein, and who attended"; "All records generated from the meeting at MCC during which it was decided that Jeffrey Epstein would be taken off suicide watch
Epstein, the wealthy financier charged with sex trafficking of minors who died at the Metropolitan Correctional Center ("MCC") on August 10, 2019. Epstein's relationships with prominent figures in politics, business, and Hollywood entertainment contribute to the public interest in Epstein and the circu
perly made by Plaintiff. 2. The records concern Jeffrey Epstein, the wealthy financier charged with sex
to BOP. The request sought: "(1) The full log of Mr. Epstein's phone calls to and from the MCC"; "(2) All ema
uch other and further relief as this Court deems just and proper. Dated: New York, New York January 30, 2020 /s/ David E. McCraw David E. McCraw Alexandra Perloff-Giles 6 EFTA00094146 Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 7 of 7 Legal Department The New York Times Company 620 8th Avenue New Yo
that request centered on records relating to the designation of Epstein as a suicide risk: "Documents showing when MCC staff held meetings regarding Jeffrey Epstein, and who attended"; "All records generated from the meeting at MCC during which it was decided that Jeffrey Epstein would be taken off suicide watch
Epstein, the wealthy financier charged with sex trafficking of minors who died at the Metropolitan Correctional Center ("MCC") on August 10, 2019. Epstein's relationships with prominent figures in politics, business, and Hollywood entertainment contribute to the public interest in Epstein and the circu
perly made by Plaintiff. 2. The records concern Jeffrey Epstein, the wealthy financier charged with sex
to BOP. The request sought: "(1) The full log of Mr. Epstein's phone calls to and from the MCC"; "(2) All ema
uch other and further relief as this Court deems just and proper. Dated: New York, New York January 30, 2020 /s/ David E. McCraw David E. McCraw Alexandra Perloff-Giles 6 EFTA00095065 Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 7 of 7 Legal Department The New York Times Company 620 8th Avenue New Yo
that request centered on records relating to the designation of Epstein as a suicide risk: "Documents showing when MCC staff held meetings regarding Jeffrey Epstein, and who attended"; "All records generated from the meeting at MCC during which it was decided that Jeffrey Epstein would be taken off suicide watch
Epstein, the wealthy financier charged with sex trafficking of minors who died at the Metropolitan Correctional Center ("MCC") on August 10, 2019. Epstein's relationships with prominent figures in politics, business, and Hollywood entertainment contribute to the public interest in Epstein and the circu
perly made by Plaintiff. 2. The records concern Jeffrey Epstein, the wealthy financier charged with sex
to BOP. The request sought: "(1) The full log of Mr. Epstein's phone calls to and from the MCC"; "(2) All ema
uch other and further relief as this Court deems just and proper. Dated: New York, New York January 30, 2020 /s/ David E. McCraw David E. McCraw Alexandra Perloff-Giles 6 EFTA00098064 Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 7 of 7 Legal Department The New York Times Company 620 8th Avenue New Yo
See Attachment 5, Plaintiff's FOIA request dated December 12, 2019. Specifically, Plaintiff sought the following records: (1) The full log of Mr. Epstein's phone calls to and from the MCC; (2) All email correspondence to and from Mr. Epstein while he was at the MCC (including any correspondence thro
Page: EFTA00015365 →ught the following records: (1) The full log of Mr. Epstein's phone calls to and from the MCC; (2) All emai
Page: EFTA00015365 →where the "chronological disciplinary records for Jeffrey Epstein at MCC" would be located. To search SENTRY for responsive information, staff used Jeffrey Epstein's unique inmate Register Number of 76318-054 and the transaction code of PD15 for disciplinary history. This SENTRY search returned the disciplinar
Page: EFTA00015368 →cords, it was determined that a search of staff emails and BEMR were the most likely ways to locate "the Post-Watch report compiled in order to take Jeffrey Epstein off suicide watch." The email search is described in Paragraphs 44-46, infra and the BEMR search is described in Paragraph 21 supra. The BOP
Page: EFTA00015371 →Entities connected to both Jeffrey Epstein and Alexandra Perloff-Giles

Richard Kahn
PERSONDarren Indyke
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
United States
LOCATION
Harry Reid
PERSON
FedEx
ORGANIZATION
Department of Justice
ORGANIZATIONMartin Weinberg
PERSON
Julie K. Brown
PERSON
Reid Weingarten
PERSONFBI
ORGANIZATION
Mark Epstein
PERSON
Ken Starr
PERSON
Bloomberg L.P.
ORGANIZATION
Geoffrey S. Berman
PERSON
Metropolitan Correctional Center
ORGANIZATION