Upjohn Co.
ORGANIZATIONIntervenor Epstein's Motion for the Court to Protect From Disclosure Grand
ORGANIZATION3
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_00059577 CONFIDENTIAL - PURSUANT TO FED. R.CCIN(F IDENTIAL DB-SONY-0022401 EFTA 00170127 EFTA01296795 Page 71 2015 U.S. Dist. LEXIS 87203, * Upjohn Co. v. United States, 449 U.S. 383, 402, 101 S. Ct. 677, 66 L. Ed. 2d 584 (1981)); see also In re Doe, 662 F.2d 1073, 1080 (4th Cir. 1981) (even under c
ereby ORDERED AND ADJUDGED that the Government shall produce documents consistent with the following Table. It is further ORDERED AND ADJUDGED that Intervenor Epstein's Motion for the Court to Protect From Disclosure Grand Jury Materials (DE 263) is GRANTED, and Petitioners' Motion to Seal (DE 267) is DENIED in light of this Court's Order at DE 326; DE 268 is hereby U
"a far stronger showing of necessity and unavailability by other means" than is needed to justify discovery of fact-based work product. Id. (quoting Upjohn Co. v. United States 14 EFTA00086458 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 15 of 51 449 U.S. 383, 402 (1981));
ereby ORDERED AND ADJUDGED that the Government shall produce documents consistent with the following Table. It is further ORDERED AND ADJUDGED that Intervenor Epstein's Motion for the Court to Protect From Disclosure Grand Jury Materials (DE 263) is GRANTED, and Petitioners' Motion to Seal (DE 267) is DENIED in light of this Court's Order at DE 326; DE 268 is hereby U
"a far stronger showing of necessity and unavailability by other means" than is needed to justify discovery of fact-based work product. Id. (quoting Upjohn Co. v. United States, 14 EFTA01657765 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 15 of 51 449 U.S. 383, 402 (1981));
ereby ORDERED AND ADJUDGED that the Government shall produce documents consistent with the following Table. It is further ORDERED AND ADJUDGED that Intervenor Epstein's Motion for the Court to Protect From Disclosure Grand Jury Materials (DE 263) is GRANTED, and Petitioners' Motion to Seal (DE 267) is DENIED in light of this Court's Order at DE 326; DE 268 is hereby U
Entities connected to both Upjohn Co. and Intervenor Epstein's Motion for the Court to Protect From Disclosure Grand

Jeffrey Epstein
PERSON
United States
LOCATIONEmmy Taylor
PERSONHickman
PERSON
Kenneth Marra
PERSON
Supreme Court
ORGANIZATIOND.C. Cir
ORGANIZATIONJane Doe
PERSONWright
PERSON
Michael Douglas
PERSON
George W. Bush
PERSONMain Justice
ORGANIZATIONthe Federal Rules of Civil
ORGANIZATIONSubpoena Duces Tecum
PERSONthe Southern District
LOCATIONRoy Black
PERSON
Michael Jackson
PERSONLeon Black
PERSONPrac. & Fed
ORGANIZATIONHickman v. Taylor
PERSON