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e whenever discovery materials were filed with the court under seal. In re Agent Orange Prod. Liab. Litig., 821 F.2d 139, 148 (2d Cir. 1987) (Agent Orange). In recent years, however, the Second Circuit has relaxed the Rule 26(c) "good cause" showing for discovery materials that are never filed with th
rotective order"); H.L. Hayden Co. of New York v. Siemens Med Sys., Inc., 797 F.2d 85, 90 (2d Cir. 1986) ("[W]e continue to adhere to our holding in Martindell [v. International Tel. and Tel. Corp., 594 F.2d 291, 294 (2d Cir. 1979)), that 'this extraordinary writ [mandamus] would hardly be available . . .
is a decision committed to the sound discretion of the trial court."' TheStreet.com, 273 F.3d at 231 (modification in original) (citing In re Agent Orange, 821 F.3d at 147) (additional citations omitted). Here, the parties in the Litigation explicitly contemplated the public disclosure of such informat
it have applied a balancing test to evaluate 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 t
r is a decision committed to the sound discretion of the trial court" TheStreet.com, 273 F.3d at 231 (modification in original) (citing In re Agent Orange, 821 F.3d at 147) (additional citations omitted). Here, the parties in the Litigation explicitly contemplated the public disclosure of such informat
it have applied a balancing test to evaluate 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 t
is a decision committed to the sound discretion of the trial court."' TheStreet.com, 273 F.3d at 231 (modification in original) (citing In re Agent Orange, 821 F.3d at 147) (additional citations omitted). Here, the parties in the Litigation explicitly contemplated the public disclosure of such informat
it have applied a balancing test to evaluate 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 t
is a decision committed to the sound discretion of the trial court."' TheStreet.com, 273 F.3d at 231 (modification in original) (citing In re Agent Orange, 821 F.3d at 147) (additional citations omitted). Here, the parties in the Litigation explicitly contemplated the public disclosure of such informat
it have applied a balancing test to evaluate 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 t
e whenever discovery materials were filed with the court under seal. In re Agent Orange Prod. Liab. Litig., 821 F.2d 139, 148 (2d Cir. 1987) (Agent Orange). In recent years, however, the Second Circuit has relaxed the Rule 26(c) "good cause" showing for discovery materials that are never filed with th
otective order."); H.L. Hayden Co. of New York v. Siemens Med Sys., Inc., 797 F.2d 85, 90 (2d Cir. 1986) ("[W]e continue to adhere to our holding in Martindell [v. International Tel. and Tel. Corp., 594 F.2d 291, 294 (2d Cir. 1979)], that `this extraordinary writ [mandamus] would hardly be available ... wh
Entities connected to both Orange and Martindell

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
Julie K. Brown
PERSON
United States
LOCATIONSecond Circuit
ORGANIZATION
Prince Andrew
PERSONSweet
PERSONColleen McMahon
PERSON
Boies Schiller
ORGANIZATIONthe Southern District
LOCATION
Southern District of New York
ORGANIZATIONChemical Bank
ORGANIZATION
Colorado
LOCATION
Virginia Giuffre
PERSONthe Second Circuit's
ORGANIZATION
George W. Bush
PERSON
Denver
LOCATION
Department of Justice
ORGANIZATION
Scarlett Johansson
PERSON