EFTA00088652.pdf

Case 1:20-cv-00833-PAE Document 38 Filed 01/15/21 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK THE NEW YORK TIMES COMPANY, Plaintiff, v. FEDERAL BUREAU OF PRISONS, Defendant. 20-CV-00833 (PAE) I 1.1 am employed by the United States Department of Justice, Federal Bureau of Prisons ("BOP"), as a Staff Attorney at the Metropolitan Correctional Center ("MCC"). My employment history with the BOP is described in a declaration I submitted in the above- captioned case on August 5, 2020 (the "Declaration"). 2. I submit this declaration in support of the BOP's motion for summary judgment and to correct certain statements in the Declaration that incorrectly described one record that BOP produced in response to Plaintiffs' FOIA requests. 3. In Paragraphs 17 and 30 of the Declaration, I stated that MCC's searches for records responsive to Plaintiff's FOIA request had located "one log book showing a visitor for Jeffrey Epstein on July 30, 2020." I have since learned that this log book showed a phone call Epstein made on July 30, 2020, not a visit that he received on that date. Specifically, the log book is an Intake Screening Phone Log kept in the Receiving & Discharging area within 1 EFTA00088652 Case 1:20-cv-00833-PAE Document 38 Filed 01/15/21 Page 2 of 2 the MCC. I advertently described the log as showing a visit, when, in fact, it shows a phone call. 4. For the same reason, Paragraph 28 of the Declaration should be corrected to reflect that the searches at MCC located one log showing a phone call made by Epstein on July 30, 2020, specifically the Intake Screening Phone Log described above. Pursuant to 28 U.S.C. § 1746, I declare under the penalty of perjury that the foregoing is true and correct. et Executed this t day of October 2020. 2 EFTA00088653