Epstein Secrets

obligations in representing Assistant United States Attorney Villafafta) in connection with an investigation conducted by the Justice Department's Office of Professional Responsibility; (2) the entry of a Protective Order; and (3) the sealing of this Application, and the accompanying Orders. BACKGROUND 1. From 2006 to 2008, t

obtain disclosure and use of grand jury materials covered by the secrecy provisions of Rule 6(e), the petitioner must show a "particularized need." Douglas Oil Co. I Petrol Stops Northwest, 441 U.S. 211, 223 (1979). The Douglas Oil Court explained that in order to pierce the veil of Rule 6(e) secrecy, [p]arti

litigation. 4 The Government asserts that the work•product doctrine applies to documents prepared by ('191 attorneys in the Department of Justice's Office of Professional Responsibility (OPR) in response to Petitioners' counsel's request for an investigation into the Government's handling of the Epstein case (DE 276-1 at 12-14). Alt

F.3d at 1347. "The district court has 'substantial discretion' in determining whether grand jury materials should be released." Id. at 1349 (quoting Douglas Oil Co. v. Petrol Stops N.W., 441 U.S. 211, 223, 99 S. Ct. 1667, 60 L. Ed. 2d 156 (1979)). For internal use only SDNY_GM_00059572 CONFIDENTIAL - PURSUANT

ocuments subject to privacy rights of victims who are not parties to this litigation Box #3 P-013227 April 23, 2008 Memo from to Privacy Act Office of Professional Responsibility re Self Reporting, Corrected Version of the previously submitted April 21, 2008 Lett Box #3 P-013226 Thm P-013230 April 21, 2008 Letter from

ed secrecy; and (3) the request is structured to cover only needed materials. United States v. Moussaoui, 483 F.3d 220, 235 (4th Cir. 2007) (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 222 (1979)). 20. Portions of Exhibits 1, 2, and 3 are relevant to a judicial proceeding, that is, the Ja