Epstein Secrets

9KNEWM 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I'd like to respectfully direct this Court to the Christenson declaration submitted by the government, and that's Document No. 24, specifically, paragraphs 49(a) through 49(s). In these paragraphs, the governm

that would also show that they were compiled for law enforcement purposes. So, overall, I think the point is that even if the Court does not adopt the Tenth Circuit's per-se rule, much of the insights or thinking of the Tenth Circuit is still going to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA0010578

9KNEWM 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I'd like to respectfully direct this Court to the Christenson declaration submitted by the government, and that's Document No. 24, specifically, paragraphs 49(a) through 49(s). In these paragraphs, the governm

that would also show that they were compiled for law enforcement purposes. So, overall, I think the point is that even if the Court does not adopt the Tenth Circuit's per-se rule, much of the insights or thinking of the Tenth Circuit is still going to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA0010570

applies a more practical approach, the documents at issue were still compiled for law enforcement purposes. See BOP MOL at 8-10. Specifically, the Christenson and Supplemental Christenson declarations explain how the records were compiled to help BOP take "proactive steps designed to prevent criminal activ

t as the Government explained, even if this Court 6 EFTA00071593 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 11 of 25 does not follow the Tenth Circuit's per se rule and instead applies a more practical approach, the documents at issue were still compiled for law enforcement purposes. See BOP MOL at 8

termination that any responsive records were exempt from disclosure, in full or in part, under FOIA Exemptions 5, 6, 7(A), 7(C), 7(E), and/or 7(F). Christenson DecL ¶ 7. 3 EFTA00071562 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 10 of 30 The Times subsequently sent BOP two additional FOIA req

No. 13-CV-7360 (JPO), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015), Judge Oetken concluded that Williams did not require the per se rule, did not adopt the Tenth Circuit's per se rule for BOP records, and followed a "practical approach," observing that "[t]he ordinary understanding of the term [law enforcement] includ

termination that any responsive records were exempt from disclosure, in full or in part, under FOIA Exemptions 5, 6, 7(A), 7(C), 7(E), and/or 7(F). Christenson DecL ¶ 7. 3 EFTA00075445 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 10 of 30 The Times subsequently sent BOP two additional FOIA req

No. 13-CV-7360 (JPO), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015), Judge Oetken concluded that Williams did not require the per se rule, did not adopt the Tenth Circuit's per se rule for BOP records, and followed a "practical approach," observing that "[t]he ordinary understanding of the term [law enforcement] includ

applies a more practical approach, the documents at issue were still compiled for law enforcement purposes. See BOP MOL at 8-10. Specifically, the Christenson and Supplemental Christenson declarations explain how the records were compiled to help BOP take "proactive steps designed to prevent criminal activ

t as the Government explained, even if this Court 6 EFTA00088614 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page 11 of 25 does not follow the Tenth Circuit's per se rule and instead applies a more practical approach, the documents at issue were still compiled for law enforcement purposes. See BOP MOL at 8

termination that any responsive records were exempt from disclosure, in full or in part, under FOIA Exemptions 5, 6, 7(A), 7(C), 7(E), and/or 7(F). Christenson DecL ¶ 7. 3 EFTA00088679 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 10 of 30 The Times subsequently sent BOP two additional FOIA req

No. 13-CV-7360 (JPO), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015), Judge Oetken concluded that Williams did not require the per se rule, did not adopt the Tenth Circuit's per se rule for BOP records, and followed a "practical approach," observing that "[t]he ordinary understanding of the term [law enforcement] includ