Epstein Secrets

ndividuals the Government considered to be victims or potential victims at the time it negotiated the non-prosecution agreement. As indicated in the Table, the Government should confer with Petitioners regarding the names of the individuals identified in these documents. If Petitioners have not been p

is greater than the need for continued secrecy"; and (3) "that their request is structured to cover only material so needed." Id. at 1348 (citing Douglas Oil Co.,N.W., 441 U.S. 211, 222 (1979)). These demanding standards apply even after the grand jury has concluded its operations. Id. The burden of demonstr

ndividuals the Government considered to be victims or potential victims at the time it negotiated the non-prosecution agreement. As indicated in the Table, the Government should confer with Petitioners regarding the names of the individuals identified in these documents. If Petitioners have not been p

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

ndividuals the Government considered to be victims or potential victims at the time it negotiated the non-prosecution agreement. As indicated in the Table, the Government should confer with Petitioners regarding the names of the individuals identified in these documents. If Petitioners have not been p

.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 (1979)). Whether proceeding under Rule 6(e)(3) or the court's inherent authority, there are well 5 EFTA_R1

ndividuals the Government considered to be victims or potential victims at the time it negotiated the non-prosecution agreement. As indicated in the Table, the Government should confer with Petitioners regarding the names of the individuals identified in these documents. If Petitioners have not been p

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

ndividuals the Government considered to be victims or potential victims at the time it negotiated the non-prosecution agreement. As indicated in the Table, the Government should confer with Petitioners regarding the names of the individuals identified in these documents. If Petitioners have not been p

.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 (1979)). Whether proceeding under Rule 6(e)(3) or the court's inherent authority, there are well 5 EFTA016