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icitly admitted that BOP operations failed when it brought criminal charges against the two BOP officers on duty the night of Epstein's suicide. See United States v. Noel, No. 19-cr-830 (AT) (S.D.N.Y.). A recent report by the Department of Justice's Office of Inspector General has revealed further problems at
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
icitly admitted that BOP operations failed when it brought criminal charges against the two BOP officers on duty the night of Epstein's suicide. See United States v. Noel, No. 19-cr-830 (AT) (S.D.N.Y.). A recent report by the Department of Justice's Office of Inspector General has revealed further problems at
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
s; (2) provide suitable quarters and provide for the safekeeping, care, and subsistence of all persons charged with or convicted of offenses against the United States, or held as witnesses or otherwise; (3) provide for the protection, instruction, and discipline of all persons charged with or convicted of offenses
Page: EFTA00015385 →.S. Department of Justice Office of Information Policy Suite 11050 1425 New York Avenue, NW Washington, DC 20530.0001 Telephone: (202) 514-3642 Alexandra Perloff-Giles, Esq. The New York Times Company 620 8th Avenue Re: Appeal No. DOJ-AP-2020-000123 New York, NY 10018 Request No. 2019-05665 aperloffgiles@nyti
Page: EFTA00015410 →Entities connected to both United States and Alexandra Perloff-Giles

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATIONLeon Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSONFBI
ORGANIZATION
Donald Trump
PERSONDarren Indyke
PERSON
Julie K. Brown
PERSONMartin Weinberg
PERSON
Richard Kahn
PERSON
Bloomberg L.P.
ORGANIZATION
Vicky Ward
PERSON
Ken Starr
PERSON
Geoffrey S. Berman
PERSON
FedEx
ORGANIZATION
William Barr
PERSON
Harry Reid
PERSON
Naomi Campbell
PERSON