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fails to address a critical question that Congress determined should be addressed by fair and neutral rule-making, not by administrative fiat. 1601 Flab Anne, Room 700, Seattle, Waslalostoa 00101 - Menotti (206) S53-1100 Fax (206) 513-0120 56 of 61 EFTA00100226 Thomas R. Kane November 16, 2011 Page 3
eate PATTERN.14 This is consistent not only with the transparency directives in the FSA,l5 but also with the advice of leading organizations such as the National Center for State Courts, which recommends that independent evaluators determine whether their independent "research findings support or contradict conclusions drawn by the
fails to address a critical question that Congress determined should be addressed by fair and neutral rule-making, not by administrative fiat. 1601 Flab Anne, Room 700, Seattle, Waslalostoa 00101 - Menotti (206) S53-1100 Fax (206) 513-0120 56 of 61 EFTA00064963 Thomas R. Kane November 16, 2011 Page 3
eate PATTERN.14 This is consistent not only with the transparency directives in the FSA,l5 but also with the advice of leading organizations such as the National Center for State Courts, which recommends that independent evaluators determine whether their independent "research findings support or contradict conclusions drawn by the
fails to address a critical question that Congress determined should be addressed by fair and neutral rule-making, not by administrative fiat. 1601 Flab Anne, Room 700, Seattle, Waslalostoa 00101 - Menotti (206) S53-1100 Fax (206) 513-0120 56 of 61 EFTA00094081 Thomas R. Kane November 16, 2011 Page 3
eate PATTERN.14 This is consistent not only with the transparency directives in the FSA,l5 but also with the advice of leading organizations such as the National Center for State Courts, which recommends that independent evaluators determine whether their independent "research findings support or contradict conclusions drawn by the
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