Epstein Secrets

ey- client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar misconduct"); United States v. Myers, 593 F.3d 338, 347 n.14 (4th Cir. 2010) (noting that exception applied where litigant "defrauded" public defender by submitting false invoices). Pe

F.3d at 1347. "The district court has 'substantial discretion' in determining whether grand jury materials should be released." Id. at 1349 (quoting Douglas Oil Co. v. Petrol Stops N.W., 441 U.S. 211, 223, 99 S. Ct. 1667, 60 L. Ed. 2d 156 (1979)). For internal use only SDNY_GM_00059572 CONFIDENTIAL - PURSUANT

ney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar misconduct"); United States v. Myers, 593 F.3d 338, 347 n.14 (4th Cir. 2010) (noting that exception applied where litigant "defrauded" public defender by submitting false invoices). Pe

.3d at 1347. "The district court has `substantial discretion' in determining whether grand jury materials should be released." Id. at 1349 (quoting Douglas Oil Co. v. Petrol Stops N.W., 441 U.S. 211, 223 (1979)). Whether proceeding under Rule 6(e)(3) or the court's inherent authority, there are well 5 EFTA_R1

ney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar misconduct"); United States v. Myers, 593 F.3d 338, 347 n.14 (4th Cir. 2010) (noting that exception applied where litigant "defrauded" public defender by submitting false invoices). Pe

ed secrecy; and (3) the request is structured to cover only needed materials. United States v. Moussaoui, 483 F.3d 220, 235 (4th Cir. 2007) (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 222 (1979)). 20. Portions of Exhibits 1, 2, and 3 are relevant to a judicial proceeding, that is, the Ja

ney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar misconduct"); United States v. Myers, 593 F.3d 338, 347 n.I4 (4th Cir. 2010) (noting that exception applied where litigant "defrauded" public defender by submitting false invoices). Pe

.3d at 1347. "The district court has 'substantial discretion' in determining whether grand jury materials should be released." Id. at 1349 (quoting Douglas Oil Co. v. Petrol Stops N.W., 441 U.S. 211, 223 (1979)). Whether proceeding under Rule 6(e)(3) or the court's inherent authority, there are well 5 EFTA016