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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
dure' is `a particular way of doing or going about the accomplishment of something.'" ACLU v. DHS, 243 F. Supp. 3d 393, 402 (S.D.N.Y. 2017) (quoting Allard K. Lowenstein Int'l Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678, 682 (2d Cir. 2010)); see NYCLU v. DHS, 771 F. Supp. 2d 289, 292 (S.D.N.Y. 2011)
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
on of the law." Exemption 7(E) contains "two alternative clauses," one covering "techniques and procedures," and the other addressing "guidelines." Allard K. Lowenstein Int'l Human Rights Project v. Dep 't of Homeland Sec., 626 F.3d 678, 680-81 (2d Cir. 2010). The first clause of Exemption 7(E) provides categorical
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
on of the law." Exemption 7(E) contains "two alternative clauses," one covering "techniques and procedures," and the other addressing "guidelines." Allard K. Lowenstein Int'l Human Rights Project v. Dep 't of Homeland Sec., 626 F.3d 678, 680-81 (2d Cir. 2010). The first clause of Exemption 7(E) provides categorical
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
dure' is `a particular way of doing or going about the accomplishment of something.'" ACLU v. DHS, 243 F. Supp. 3d 393, 402 (S.D.N.Y. 2017) (quoting Allard K. Lowenstein Int'l Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678, 682 (2d Cir. 2010)); see NYCLU v. DHS, 771 F. Supp. 2d 289, 292 (S.D.N.Y. 2011)
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
on of the law." Exemption 7(E) contains "two alternative clauses," one covering "techniques and procedures," and the other addressing "guidelines." Allard K. Lowenstein Int'l Human Rights Project v. Dep 't of Homeland Sec., 626 F.3d 678, 680-81 (2d Cir. 2010). The first clause of Exemption 7(E) provides categorical
Entities connected to both Christenson and Allard K. Lowenstein

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Supreme Court
ORGANIZATIONNicholas Tartaglione
PERSON
George W. Bush
PERSONthe Southern District
LOCATION
Audrey Strauss
PERSONFederal Bureau of Prisons
ORGANIZATION
Doherty
PERSON
THE NEW YORK TIMES COMPANY
ORGANIZATIONTova Noel
PERSONShapiro
PERSONGarcia
PERSON
Homeland Security
ORGANIZATION
Hopkins
ORGANIZATION
The New York Times
ORGANIZATION
The Washington Post
ORGANIZATIONthe Tenth Circuit's
ORGANIZATIONMichael Thomas
PERSON