Epstein Secrets

mmarize any CDM or portions thereof, absent leave of the Court to file the document or portion thereof under seal in accordance with Local Rules of the United States District Court for the Southern District of Florida. See Exhibit 1, Proposed Protective Confidentiality Order. EFTA00605751 In support of this motion, the Inter

rticularly important since "[t]he overwhelming majority of documents disclosed during discovery are likely irrelevant to the underlying issues...." Federal Trade Commission v. Abbvie Products LLC, 713 F.3d 54, 63 (1 1 'h Cir. 2013). Therefore, "[s]uch documents, prior to admission into the record in support of a motion

rt file O Destroyed 0 Returned to the party or counsel for the party, as identified above A`tancy for: United Stales of Vifierica EFTA00179092 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE: GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-64 AND OLY-64 FGJ 07-103 (WPB) MOTION FOR LEAVE TO FILE SUPPLE

easonable certainty that the privilege applies, the burden is not met." United States v. Blackburn, 538 F. Supp. 1376, 1382 (M.D. Fl. 1982) (citing Federal Trade Commission v. TRW, Inc., 628 F.2d 207, 213 (D.C. Cir. 1980); In re Katz, 623 F.2d 122, 125 (2d Cir. 1980); United States v. Landof, 591 F.2d 36, 38 (9th Cir. 1

mmarize any CDM or portions thereof, absent leave of the Court to file the document or portion thereof under seal in accordance with Local Rules of the United States District Court for the Southern District of Florida. See Exhibit 1, Proposed Protective Confidentiality Order. EFTA00191290 Case 9:08-cv-80736-KAM Document 247

rticularly important since "[t]he overwhelming majority of documents disclosed during discovery are likely irrelevant to the underlying issues...." Federal Trade Commission. Abbvie Products LLC, 713 F.3d 54, 63 (11'" Cir. 2013). Therefore, "[s]uch documents, prior to admission into the record in support of a motion or