Epstein Secrets

te process because the litigants and the courts assume that the sole purpose of discovery is to assist trial preparation") (quoting United States v. Anderson, 799 F.2d 1438, 1441 (11'h Cir. 1986; emphasis in original). See also Anderson, 799 F.2d at 1441 ("Historically, discovery materials were not avail

arm; [2] the precision with which the order is drawn; [3] the availability of a less onerous alternative; and [4] the duration of the order." In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (11th Cir. 1987). H. THERE IS GOOD CAUSE TO ISSUE THE PROTECTIVE CONFIDENTIALITY ORDER Even though the Eleventh Circuit has rul

vate process because the litigants and the courts assume that the sole purpose of discovery is to assist trial preparation") (quoting United States" Anderson, 799 F.2d 1438, 1441 (11th Cir. 1986; emphasis in original). See also Anderson, 799 F.2d at 1441 ("Historically, discovery materials were not avail

arm; [2] the precision with which the order is drawn; [3] the availability of a less onerous alternative; and [4] the duration of the order." In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (11th Cir. 1987). H. THERE IS GOOD CAUSE TO ISSUE THE PROTECTIVE CONFIDENTIALITY ORDER Even though the Eleventh Circuit has rul

e process because the litigants and the courts assume that the sole purpose of discovery is to assist trial preparation@) (quoting United States v. Anderson, 799 F.2d 1438, 1441 (11t1 Cir. 1986; emphasis in original). See also Anderson, 799 F.2d at 1441 (AHistorically, discovery materials were not avail

harm; [2] the precision with which the order is drawn; [3] the availability of a less onerous alternative; and [4] the duration of the order.@ In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (11th Cir. 1987). II. THERE IS GOOD CAUSE TO ISSUE THE PROTECTIVE CONFIDENTIALITY ORDER Even though the Eleventh Circuit has r