From: ' (USANYS)" ci To: ' (USANYS)" Cc: 'cUllili mm> USANYS)" ci k so Subject: RE: Jeffrey Epstein-Related Touhy Requests - Times FOIA Action Date: Mon, 10 Feb 2020 23:38:11 +0000 (USANYS)" We have 30 days to Answer in a FOIA case. I don't think we have a basis for a Rule 12 motion here (in FOIA we generally don't). Generally, FOIA cases go straight to summary judgment (after the Court sets a schedule, usually submitted on consent by the parties), where we defend agency withholdings based on a declaration from the agency. I need to see the underlying FOIA request here and get more details on BOP's response. My understanding is that they categorically refused to disclose any documents. Categorical refusals can be difficult to defend, although they are allowed under certain FOIA exemptions. The Times is an aggressive but not unreasonable FOIA plaintiff. Once we have the requests, we might check in about whether or not it would be possible for BOP to release anything. Or, we can check in about how best to maintain the categorical withholdings. I'll circle back once I have a more substantive conversation with BOP (BOP counsel is out tomorrow, but should follow up later in the week). Thanks, From: (USANYS) Sent: Monday, February 10, 2020 4:35 PM To: (USANYS) Cc: (USANYS) <Ma; (USANYS) Subject: RE: Jeffrey Epstein-Related Touhy Requests - Times FOIA Action Thanks. What would your proposed response be? From: (USANYS) Sent: Monday, February 10, 2020 4:01 PM To: (USANYS) Cc: (USANYS) ; (USANYS) Subject: RE: Jeffrey Epstein-Related Touhy Requests - Times FOIA Action Sorry, included it on the first email, but not later. Here it is. Also, FYI, it sounds like the FOIA BOP contact is going to be who's in DC. Thanks. From: (USANYS) Sent: Monday, February 10, 2020 1:04 PM To: (USANYS) Cc: (USANYS) (USANYS) Subject: RE: Jeffrey Epstein-Related Touhy Requests - Times FOIA Action Got it. Do you mind sending the complaint, then?