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t 1, United States v. Noel, No. 19-cr-830 (AT) (S.D.N.Y.), Dkt. No. 22; Memorandum of Law of the United States of America in Opposition to Defendant Michael Thomas's Motion to Compel, United States v. Noel, at 8-9, No. 19-cr-830 (AT) (S.D.N.Y.), Dkt. No. 35. The fact that materials at issue have been disclosed t
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
t 1, United States v. Noel, No. 19-cr-830 (AT) (S.D.N.Y.), Dkt. No. 22; Memorandum of Law of the United States of America in Opposition to Defendant Michael Thomas's Motion to Compel, United States v. Noel, at 8-9, No. 19-cr-830 (AT) (S.D.N.Y.), Dkt. No. 35. The fact that materials at issue have been disclosed t
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
t 1, United States v. Noel, No. 19-cr-830 (AT) (S.D.N.Y.), Dkt. No. 22; Memorandum of Law of the United States of America in Opposition to Defendant Michael Thomas's Motion to Compel, United States v. Noel, at 8-9, No. 19-cr-830 (AT) (S.D.N.Y.), Dkt. No. 35. The fact that materials at issue have been disclosed t
t as the Government explained, even if this Court 6 EFTA00099607 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
Entities connected to both Michael Thomas's and the Tenth Circuit's

Jeffrey Epstein
PERSONthe Southern District
LOCATIONTova Noel
PERSON
United States
LOCATIONNicholas Tartaglione
PERSON
THE NEW YORK TIMES COMPANY
ORGANIZATION
Audrey Strauss
PERSONFederal Bureau of Prisons
ORGANIZATION
Doherty
PERSONGarcia
PERSON
The New York Times
ORGANIZATION
Human Rights Watch
ORGANIZATION
Hopkins
ORGANIZATIONRobbins Tire & Rubber Co.
ORGANIZATIONFavish
PERSONChristenson
PERSONthe Acting United States
ORGANIZATIOND.C. Cir
ORGANIZATIONHomeland Sec
ORGANIZATIONRadcliffe
PERSON