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a were the defendant's denials of various sexual activities, not honest answers that would have been quite different. In part for that reason, Judge Sweet authorized the deposition at the outset. Second, the Government was not a party to the civil unsealing litigation and did not have an opportunity t
ssued a "subpoena for the production of documents as part of an ongoing investigation." (Id. at 25). In support of her argument, the defendant cites Palmieri where the Second Circuit, applying Martindell, reversed the district court's decision granting the state Attorney General's motion to intervene to
er the protective order was improvidently granted or whether the government had made a showing of exceptional circumstances or a compelling need"); Palmieri, 779 F.2d at 862 (reversing district court's modification of protective orders where district court did not make an "express finding" of improvidenc
allows a protective order to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N.Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initial
a were the defendant's denials of various sexual activities, not honest answers that would have been quite different. In part for that reason, Judge Sweet authorized the deposition at the outset. Second, the Government was not a party to the civil unsealing litigation and did not have an opportunity t
er the protective order was improvidently granted or whether the government had made a showing of exceptional circumstances or a compelling need"); Palmieri, 779 F.2d at 862 (reversing district court's modification of protective orders where district court did not make an "express finding" of improvidenc
allows a protective order to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N.Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initial
ssued a "subpoena for the production of documents as part of an ongoing investigation." (Id. at 25). In support of her argument, the defendant cites Palmieri where the Second Circuit, applying Martindell, reversed the district court's decision granting the state Attorney General's motion to intervene to
a were the defendant's denials of various sexual activities, not honest answers that would have been quite different. In part for that reason, Judge Sweet authorized the deposition at the outset. Second, the Government was not a party to the civil unsealing litigation and did not have an opportunity t
er the protective order was improvidently granted or whether the government had made a showing of exceptional circumstances or a compelling need"); Palmieri, 779 F.2d at 862 (reversing district court's modification of protective orders where district court did not make an "express finding" of improvidenc
allows a protective order to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N. Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initi
grand jury that had issued a alliena for the production of documents as parl'of an ongoing ation5). In support of her argument, the defendant cites Palmieri where the Second Circuit, applying Martindell, reversed the district court's decision granting the state Attorney General's motion to intervene to
a were the defendant's denials of various sexual activities, not honest answers that would have been quite different. In part for that reason, Judge Sweet authorized the deposition at the outset. Second, the Government was not a party to the civil unsealing litigation and did not have an opportunity t
er the protective order was improvidently granted or whether the government had made a showing of exceptional circumstances or a compelling need"); Palmieri, 779 F.2d at 862 (reversing district court's modification of protective orders where district court did not make an "express finding" of improvidenc
allows a protective order to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N.Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initial
ssued a "subpoena for the production of documents as part of an ongoing investigation." (Id. at 25). In support of her argument, the defendant cites Palmieri where the Second Circuit, applying Martindell, reversed the district court's decision granting the state Attorney General's motion to intervene to
a were the defendant's denials of various sexual activities, not honest answers that would have been quite different. In part for that reason, Judge Sweet authorized the deposition at the outset. Second, the Government was not a party to the civil unsealing litigation and did not have an opportunity t
allows a protective order to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N.Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initial
Parties' reliance."). 79 EFTA00100046 cau PPIal (Id. washy a granrad issulaubeaurnalMI an In support of her argument, the defendant cites Palmieri where the Second Circuit, applying Martind ell, reversed the district court's decision granting the state Attorney General's motion to intervene to
her the protective order was improvidently granted or whether the government had made a showing of exceptionalcircumstances or a compelling need"); Palmieri, 779 F.2d at 862 (reversing district court's modification o fprotective orders where district court did not make an "express finding" of improvidenc
686 , To Be Filed Under Seal statutory and common law privacy concerns. (Dkt. No. 38 at 1.) Maxwell submitted a proposed form of order for Judge Sweet's consideration. (Dkt. No. 39-1.) Giuffre represented that she "[did] not oppose the entrance [sic] of a Protective Order in this case, but [did] o
al by motion to quash or modify the subpoena ... or to seek permissive intervention in the private action.") (internal quotations omitted); but see Palmieri v. State of N Y., 779 F.2d 861, 862 (2d Cir. 1985) (considering appeal where the New York State Attorney General, rather than the subject of the subpoena, w
er is "improvidently granted" where the presiding judge "reasonably should have recognized that [it] would facilitate or further criminal activity." Palmieri, 779 F.2d at 865-66. But there is absolutely no evidence that the district court harbored any such realization; indeed, at the time Judge Sweet ent
(9th Cir. 2016) 4, 5, 11 Katz v. United States, 389 U.S. 347 (1967) 2, 6 Murphy v. Waterfront Comm 'n of New York Harbor, 378 U.S. 52 (1964) 2 Palmieri v. State of New York, 779 F.2d 861 (2d Cir. 1985) 14 People v. Gutierrez, 222 P.3d 925 (Cob. 2009) 10 People v. Mason, 989 P.2d 757 (Colo. 1999
Page: EFTA00015305 →idential information at the conclusion of the case, including Maxwell's deposition transcripts refused to do so although ordered to do so by Judge Sweet.' In its application to the governmen Not only did the government misunderstand how the Protective Order worked, but its argument also supports r
Page: EFTA00015313 →Entities connected to both Sweet and Palmieri v. State

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
Julie K. Brown
PERSON
Virginia Giuffre
PERSON
United States
LOCATION
Bradley Edwards
PERSONSigrid McCawley
PERSON
George W. Bush
PERSONJane Doe
PERSONJeffrey Pagliuca
PERSON
Prince Andrew
PERSONMartindell
PERSONthe Southern District
LOCATION
Alan Dershowitz
PERSON
Colorado
LOCATION
Stephen Hawking
PERSONSecond Circuit
ORGANIZATIONColleen McMahon
PERSONMartin Weinberg
PERSON