3-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 FBI records, and followed a "practical approach," observing that 9 EFTA00069320 "[t]he ordinary understanding of the term [law en