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- Module 05 — Appeal strategy + lawyer workflow
- ===== Appeal as a deadline lever ===== Often the FIRST APPEAL is more important than the original RTI. The FAA ... areer incentive to avoid a CIC penalty — a strong First Appeal often gets the disclosure where the PIO refused. **Tactical first appeal**: file even if the PIO partially complied — to push for the rest. Costs nothing (no fee for First Appeal). Adds a second lever. ===== CIC/SIC and the 90-