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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
X MEMORANDUM OF LAW IN SUPPORT 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 D
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
X MEMORANDUM OF LAW IN SUPPORT 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 Fa
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
FOIA; and 33. Grant Plaintiff such 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
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
FOIA; and 33. Grant Plaintiff such 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
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
FOIA; and 33. Grant Plaintiff such 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
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
FOIA; and 33. Grant Plaintiff such 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
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
FOIA; and 33. Grant Plaintiff such 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
ow He Hanged Himself in Suicide, N.Y. Times (Aug. 16, 2019) 7 Ali Watkins, Danielle Ivory & Christina Goldbaum, Inmate 76318-054: The Last Days of Jeffrey Epstein (Aug. 17, 2019) 5, 6 Julie K. Brown, Jeffrey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself, Brother Says, Miami Herald (Nov. 14, 2
ords could interfere with the law enforcement proceedings it cites—the prosecution of murder defendant Nicholas Tartaglione, who shared a cell with Epstein for a brief period of time, and the prosecution of the two correctional officers who failed to perform prisoner counts at the time of Epstein's suic
0 OTHER AUTHORITIES Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in
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
ow He Hanged Himself in Suicide, N.Y. Times (Aug. 16, 2019) 7 Ali Watkins, Danielle Ivory & Christina Goldbaum, Inmate 76318-054: The Last Days of Jeffrey Epstein (Aug. 17, 2019) 5, 6 Julie K. Brown, Jeffrey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself, Brother Says, Miami Herald (Nov. 14, 2
ords could interfere with the law enforcement proceedings it cites—the prosecution of murder defendant Nicholas Tartaglione, who shared a cell with Epstein for a brief period of time, and the prosecution of the two correctional officers who failed to perform prisoner counts at the time of Epstein's suic
0 OTHER AUTHORITIES Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in
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
ow He Hanged Himself in Suicide, N.Y. Times (Aug. 16, 2019) 7 Ali Watkins, Danielle Ivory & Christina Goldbaum, Inmate 76318-054: The Last Days of Jeffrey Epstein (Aug. 17, 2019) 5, 6 Julie K. Brown, Jeffrey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself, Brother Says, Miami Herald (Nov. 14, 2
ords could interfere with the law enforcement proceedings it cites—the prosecution of murder defendant Nicholas Tartaglione, who shared a cell with Epstein for a brief period of time, and the prosecution of the two correctional officers who failed to perform prisoner counts at the time of Epstein's suic
0 OTHER AUTHORITIES Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in
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
Entities connected to both Jeffrey Epstein and David E. McCraw

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
PERSONFederal Bureau of Prisons
ORGANIZATION