Case 1:20-cv-00833-PAE Document 12 Filed 04/15/20 Page 1 of 2 U.S. Department of Justice United States Attorney Southern District of New York 86 Cheettbers sum New York New Yoe* 10007 April 15, 2020 By ECF The Honorable Paul A. Engelmayer United States District Judge Southern District of New York 40 Foley Square New York, NY 10007 Re: The New York Times Co. v. Federal Bureau of Prisons, 20 Civ. 833 (PAE) Dear Judge Engelmayer: This Office represents defendant the Federal Bureau of Prisons ("BOP") in this Freedom of Information Act ("FOIA"), 5 U.S.C. § 552, action brought by plaintiff the New York Times Company (the "Times"). The parties respectfully submit this joint letter pursuant to the Court's Orders of March 5 and 13, 2020. See Dkt. Nos. 8, 10. The initial pretrial conference in this matter is currently scheduled to be held at 11:00 AM on April 20, 2020. See Dkt. No. 10. The parties respectfully propose that the initial pretrial conference be adjourned if this letter sufficiently addresses the present issues in this case. On January 30, 2020, the Times filed its complaint initiating this action. See Dkt. No. 1. The Times seeks, pursuant to FOIA, the release of certain documents related to Jeffrey Epstein, the deceased defendant in United States v. Jeffrey Epstein, No. 19-CRIM-00490 (S.D.N.Y.), and his BOP custody. On March 4, 2020, the Government filed its Answer to the Times's complaint. See Dkt. No. 7. BOP has not produced any documents in response to the Times's request. The Government's position is that any documents potentially responsive to the Times's request are exempt from disclosure under FOIA, including under FOIA Exemption 7(A), which protects from disclosure records or information compiled for law enforcement purposes "to the extent that the production of such law enforcement records or information . . . could reasonably be expected to interfere with enforcement proceedings?' 5 U.S.C. § 552(bX7)(A). The parties anti