Epstein Secrets

s Proposed Protective Order included a provision that stated that all discovery produced by the Government "[s]hall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action."

nd Circuit have applied the standard for modification of protective orders in the civil context to the criminal context. See, e.g., United States v. Calderon, No. 3: I5-CR-25 (J0-1), 2017 WL 6453344, at •2 (D. Conn. Dec. I, 2017) (applying the civil standard for the modification of a protective order in

that any and all discovery material produced to the defendant by the Government, regardless of designation, "[s]hall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action."

are of any. Though precedent on this issue appears to be somewhat sparse— perhaps because few defendants attempt such a maneuver—see United States v. Calderon, 15 Cr. 025, 2017 WL 6453344, at *3 (D. Conn. Dec. I, 2017) (discussing the relative lack of specific guidance in the context of an application to

s Proposed Protective Order included a provision that stated that all discovery produced by the Government "[s]hall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action."

nd Circuit have applied the standard for modification of protective orders in the civil context to the criminal context. See, e.g., United States v. Calderon, No. 3: I5-CR-25 (JCR), 2017 WL 6453344, at *2 (D. Conn. Dec. I, 2017) (applying the civil standard for the modification of a protective order in a