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York United States Courthouse New York, New York 10007 Re: In re Application to Unseal Civil Discovery Materials, USAO No. 2018R01618 Dear Judge Sweet: The Government writes respectfully in connection with its sealed application and proposed order pursuant to the All Writs Act, Title 28, United St
valuate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access to discovery materials from a civil
York United States Courthouse New York, New York 10007 Re: In re Application to Unseal Civil Discovery Materials, USAO No. 2018R01618 Dear Judge Sweet: The Government writes respectfully in connection with its sealed application and proposed order pursuant to the All Writs Act, Title 28, United St
valuate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access to discovery materials from a civil
York United States Courthouse New York, New York 10007 Re: In re Application to Unseal Civil Discovery Materials, USAO No. 2018R01618 Dear Judge Sweet: The Government writes respectfully in connection with its sealed application and proposed order pursuant to the All Writs Act, Title 28, United St
valuate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access to discovery materials from a civil
ome provisions and adding language that confidential material could be disclosed to law enforcement. (Def. Mot. 3, Ex. B). On March 18, 2016, Judge Sweet entered a protective order governing the discovery and dissemination of confidential information after the parties agreed to the form of the order o
s Five and Six under the Due Process Clause, the Fourth Amendment, the Fifth Amendment, and the Second Circuit's decision in Martindell v. TeL and TeL Corp., 594 F.2d 291 (2d Cir. 1979). (Def. Mots. 3 & 11). In particular, the defendant contends that the Government violated the Second Circuit's decision
Entities connected to both Sweet and TeL Corp.

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
George W. Bush
PERSON
Prince Andrew
PERSONMartindell
PERSON
Boies Schiller
ORGANIZATIONSouthern District
LOCATION
Department of Justice
ORGANIZATIONSubpoena Duces
PERSON
Robert W. Sweet
PERSONChemical Bank
ORGANIZATIONBranzburg v. Hayes
PERSON
Boies Schiller & Flexner LLP
ORGANIZATION
Woody Allen
PERSONthe Protective Order
ORGANIZATION
Orange
LOCATIONMeserve, Mumper & Hughes
ORGANIZATIONRoach
PERSONInternational Tel
ORGANIZATION