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ut tempering or censoring their plea/settlement communications to avoid making statements that could later come back to haunt their clients in TMZ, the National Enquirer or the grocery store tabloids. c. The Harm Extends To Mr. Epstein, His Counsel, And Beyond We know of no case that has authorized the wholesale pu
EQUEST FOR A PROTECTIVE CONFIDENTIALITY ORDER IS `GOOD CAUSE' Citing Brown v. Advantage Eng I, Inc., 960 F.2d 1013 (11th Cir. 1992), and Wilson v. American Motors Corp., 759 F.2d 1568 (11th Cir. 1985), the Court has requested that we set forth "the extraordinary circumstances or particularized needs necessitating a
ut tempering or censoring their plea/settlement communications to avoid making statements that could later come back to haunt their clients in TMZ, the National Enquirer or the grocery store tabloids. c. The Harm Extends To Mr. Epstein, His Counsel, And Beyond We know of no case that has authorized the wholesale pu
EQUEST FOR A PROTECTIVE CONFIDENTIALITY ORDER IS `GOOD CAUSE' Citing Brown I. Advantage Eng g, Inc., 960 F.2d 1013 (11th Cir. 1992), and Wilson I. American Motors Corp., 759 F.2d 1568 (11th Cir. 1985), the Court has requested that we set forth "the extraordinary circumstances or particularized needs necessitating a
ut tempering or censoring their plea/settlement communications to avoid making statements that could later come back to haunt their clients in TMZ, the National Enquirer or the grocery store tabloids. c. The Harm Extends To Mr. Epstein, His Counsel, And Beyond We know of no case that has authorized the wholesale
REQUEST FOR A PROTECTIVE CONFIDENTIALITY ORDER IS >GOOD CAUSE= Citing Brown v. Advantage Eng=g, Inc, 960 F.2d 1013 (11th Cir. 1992), and Wilson v American Motors Corp., 759 F.2d 1568 (11th Cir. 1985), the Court has requested that we set forth Athe extraordinary circumstances or particularized needs necessitating a
Entities connected to both the National Enquirer and American Motors Corp.

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Alan Dershowitz
PERSONJane Doe
PERSON
Cynthia Nixon
PERSONSeattle Times Co.
ORGANIZATION
Julie K. Brown
PERSON
Prince Charles
PERSON
Anderson
PERSON
Bradley Cooper
PERSON
Wagner
PERSON
Samsung
ORGANIZATIONHerman
PERSON
Apple
ORGANIZATION
Scarlett Johansson
PERSONLeon Black
PERSONthe Federal Rules of Civil
ORGANIZATIONFirestone
ORGANIZATIONWarner Communications
ORGANIZATIONAlexander Grant & Co. Litigation
ORGANIZATION