Epstein Secrets

it A. Background As described in the Application, the Government has served a grand jury subpoena (the "Subpoena") upon Boies Schiller & Flexner ("Boies Schiller") requiring the production of copies of discovery and related materials related to the Litigation. The Subpoena was validly issued pursuant to an o

s the materials at issue here appear not to be of the sort that ordinarily would provide protection against Government investigation. See 3 To read Martindeli more broadly would not only be contrary to the opinion itself, as described above, but would risk rendering that opinion in even further conflict wi

it A. Background As described in the Application, the Government has served a grand jury subpoena (the "Subpoena") upon Boies Schiller & Flexner ("Boies Schiller") requiring the production of copies of discovery and related materials related to the Litigation. The Subpoena was validly issued pursuant to an o

s the materials at issue here appear not to be of the sort that ordinarily would provide protection against Government investigation. See 3 To read Martindeli more broadly would not only be contrary to the opinion itself, as described above, but would risk rendering that opinion in even further conflict wi

17 WL 2834260 (E.D. Pa. June 30, 2017) 17 Manhattan Review LLC v. Ytni, 16 Civ. 0102 (LAK) (JCF), 2017 WL 11455317 (S.D.N.Y. Sept. 21, 2017) 17 Martindeli v. Intl Tel. & Tel. Cotp., 594 F.2d 291 (2d Cir. 1979) 12, 13 S.E.C. v. TheStreet.Com, 273 F.3d 222 (2d Cir. 2001) 12 Stewart v. Hudson Hall LLC

o prosecutors for the purpose of fomenting an investigation. But I am not faced with that situation. Nothing in this record suggests to me that or Boies Schiller had anything to do with the Government's decision to convene a grand jury to look into the matters that were the subject of the Action. On the con

An Identical Gambit By The Government 10 ARGUMENT 11 A. Pursuant To Its Inherent Power, This Court Should Suppress The Evidence Obtained From Boies Schiller, And Dismiss Counts Five And Six, Which Are The Fruits Of That Evidence 11 I. The role of protective orders in civil litigation 11 2. The go

17 WL 2834260 (E.D. Pa. June 30, 2017) 17 Manhattan Review LLC v. Ytni, 16 Civ. 0102 (LAK) (JCF), 2017 WL 11455317 (S.D.N.Y. Sept. 21, 2017) 17 Martindeli v. Intl Tel. & Tel. Cotp., 594 F.2d 291 (2d Cir. 1979) 12, 13 S.E.C. v. TheStreet.Com, 273 F.3d 222 (2d Cir. 2001) 12 Stewart v. Hudson Hall LLC