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U.S. 168, 184 (1975)). A document is "predecisional" when it is "prepared in order to assist an agency decisionmaker in arriving at his decision." Grumman, 421 U.S. at 184. While a document is predecisional if it "precedes, in temporal sequence, the `decision' to which it relates," Grand Cent. P 'ship
.4 (2d Cir. 1985), "even commonly known procedures may be protected from disclosure if the disclosure could reduce or nullify their effectiveness," Judicial Watch, Inc. v. U.S. Dep't of Commerce, 337 F. Supp. 2d 146, 181 (D.D.C. 2004). Exemption 7(E) sets a "low bar for the agency to justify withholding," Blackwell
U.S. 168, 184 (1975)). A document is "predecisional" when it is "prepared in order to assist an agency decisionmaker in arriving at his decision." Grumman, 421 U.S. at 184. While a document is predecisional if it "precedes, in temporal sequence, the 'decision' to which it relates," Grand Cent. P'ship,
4, 17 John Doe Agency v. John Doe Corp., 493 U.S. 146 (1 989) 4 Jordan v. U.S. Dep .t of Justice, M8 F.3d 1188 (10th Cir. 2 011) 9, 10, 21, 22 Judicial Watch, Inc. v. U.S. Dept of Commerce, 337 F. Supp. 2d 146 (D.D.C. 2004) 20, 21 Kansi v. U.S. Depst of Justice, 11 F. Supp. 2d 42 (D.D.C. 1998) 8 Kay v. F.C
U.S. 168, 184 (1975)). A document is "predecisional" when it is "prepared in order to assist an agency decisionmaker in arriving at his decision." Grumman, 421 U.S. at 184. While a document is predecisional if it "precedes, in temporal sequence, the 'decision' to which it relates," Grand Cent. P'ship,
4, 17 John Doe Agency v. John Doe Corp., 493 U.S. 146 (1 989) 4 Jordan v. U.S. Dep .t of Justice, M8 F.3d 1188 (10th Cir. 2 011) 9, 10, 21, 22 Judicial Watch, Inc. v. U.S. Dept of Commerce, 337 F. Supp. 2d 146 (D.D.C. 2004) 20, 21 Kansi v. U.S. Depst of Justice, 11 F. Supp. 2d 42 (D.D.C. 1998) 8 Kay v. F.C
U.S. 168, 184 (1975)). A document is "predecisional" when it is "prepared in order to assist an agency decisionmaker in arriving at his decision." Grumman, 421 U.S. at 184. While a document is predecisional if it "precedes, in temporal sequence, the 'decision' to which it relates," Grand Cent. P'ship,
4, 17 John Doe Agency v. John Doe Corp., 493 U.S. 146 (1 989) 4 Jordan v. U.S. Dep .t of Justice, M8 F.3d 1188 (10th Cir. 2 011) 9, 10, 21, 22 Judicial Watch, Inc. v. U.S. Dept of Commerce, 337 F. Supp. 2d 146 (D.D.C. 2004) 20, 21 Kansi v. U.S. Depst of Justice, 11 F. Supp. 2d 42 (D.D.C. 1998) 8 Kay v. F.C
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