Epstein Secrets

F. Supp. 2d 356, 366 (S.D.N.Y. 2002). The agency must demonstrate that its search was "reasonably calculated to discover the requested documents." SafeCard Servs., Inc. v. S.E.C., 926 F.2d 1197, 328 (D.C. Cir. 1991). An agency'ssearch may be reasonable even if it does not return every responsive document. See

.4 (2d Cir. 1985), "even commonly known procedures may be protected from disclosure if the disclosure could reduce or nullify their effectiveness," Judicial Watch, Inc. v. U.S. Dep't of Commerce, 337 F. Supp. 2d 146, 181 (D.D.C. 2004). Exemption 7(E) sets a "low bar for the agency to justify withholding," Blackwell

F. Supp. 2d 356, 366 (S.D.N.Y. 2002). The agency must demonstrate that its search was "reasonably calculated to discover the requested documents." SafeCard Servs., Inc. v. S.E. C., 926 F.2d 1197, 328 (D.C. Cir. 1991). An agency's search may be reasonable even if it does not return every responsive document. S

4, 17 John Doe Agency v. John Doe Corp., 493 U.S. 146 (1 989) 4 Jordan v. U.S. Dep .t of Justice, M8 F.3d 1188 (10th Cir. 2 011) 9, 10, 21, 22 Judicial Watch, Inc. v. U.S. Dept of Commerce, 337 F. Supp. 2d 146 (D.D.C. 2004) 20, 21 Kansi v. U.S. Depst of Justice, 11 F. Supp. 2d 42 (D.D.C. 1998) 8 Kay v. F.C

F. Supp. 2d 356, 366 (S.D.N.Y. 2002). The agency must demonstrate that its search was "reasonably calculated to discover the requested documents." SafeCard Servs., Inc. v. S.E. C., 926 F.2d 1197, 328 (D.C. Cir. 1991). An agency's search may be reasonable even if it does not return every responsive document. S

4, 17 John Doe Agency v. John Doe Corp., 493 U.S. 146 (1 989) 4 Jordan v. U.S. Dep .t of Justice, M8 F.3d 1188 (10th Cir. 2 011) 9, 10, 21, 22 Judicial Watch, Inc. v. U.S. Dept of Commerce, 337 F. Supp. 2d 146 (D.D.C. 2004) 20, 21 Kansi v. U.S. Depst of Justice, 11 F. Supp. 2d 42 (D.D.C. 1998) 8 Kay v. F.C

F. Supp. 2d 356, 366 (S.D.N.Y. 2002). The agency must demonstrate that its search was "reasonably calculated to discover the requested documents." SafeCard Servs., Inc. v. S.E. C., 926 F.2d 1197, 328 (D.C. Cir. 1991). An agency's search may be reasonable even if it does not return every responsive document. S

4, 17 John Doe Agency v. John Doe Corp., 493 U.S. 146 (1 989) 4 Jordan v. U.S. Dep .t of Justice, M8 F.3d 1188 (10th Cir. 2 011) 9, 10, 21, 22 Judicial Watch, Inc. v. U.S. Dept of Commerce, 337 F. Supp. 2d 146 (D.D.C. 2004) 20, 21 Kansi v. U.S. Depst of Justice, 11 F. Supp. 2d 42 (D.D.C. 1998) 8 Kay v. F.C