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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
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)
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
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
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
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
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
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)
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
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
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
edure' 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 Intl 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)
Entities connected to both the Tenth Circuit's and Allard K. Lowenstein

Jeffrey Epstein
PERSON
United States
LOCATION
Audrey Strauss
PERSONthe Southern District
LOCATIONTova Noel
PERSON
THE NEW YORK TIMES COMPANY
ORGANIZATIONNicholas Tartaglione
PERSON
The New York Times
ORGANIZATIOND.C. Cir
ORGANIZATIONRadcliffe
PERSONFavish
PERSONChristenson
PERSONJudicial Watch, Inc.
ORGANIZATION
Doherty
PERSONthe Acting United States
ORGANIZATIONGarcia
PERSONNat'l Aeronautics & Space Admin
ORGANIZATION
Hopkins
ORGANIZATION
Human Rights Watch
ORGANIZATIONHomeland Sec
ORGANIZATION