Epstein Secrets

EQUEST FOR A PROTECTIVE CONFIDENTIALITY ORDER IS `GOOD CAUSE' Citing Brown v. Advantage Eng I, Inc., 960 F.2d 1013 (11th Cir. 1992), and Wilson v. American Motors Corp., 759 F.2d 1568 (11th Cir. 1985), the Court has requested that we set forth "the extraordinary circumstances or particularized needs necessitating a

andard of Rule 26(c) applies. Chicago Tribune Co. v. Bridgestone/Firestone Inc., 263 F.3d 1304, 1310 (11th Cir. 2001) ("The district court required Firestone to meet a compelling interest standard. To the extent this was predicated on a constitutional right of access, it was error"). a. Heightened Scrut

EQUEST FOR A PROTECTIVE CONFIDENTIALITY ORDER IS `GOOD CAUSE' Citing Brown I. Advantage Eng g, Inc., 960 F.2d 1013 (11th Cir. 1992), and Wilson I. American Motors Corp., 759 F.2d 1568 (11th Cir. 1985), the Court has requested that we set forth "the extraordinary circumstances or particularized needs necessitating a

andard of Rule 26(c) applies. Chicago Tribune Co. I. Bridgestone/Firestone Inc., 263 F.3d 1304, 1310 (11th Cir. 2001) ("The district court required Firestone to meet a compelling interest standard. To the extent this was predicated on a constitutional right of access, it was error"). a. Heightened Scrut

REQUEST FOR A PROTECTIVE CONFIDENTIALITY ORDER IS >GOOD CAUSE= Citing Brown v. Advantage Eng=g, Inc, 960 F.2d 1013 (11th Cir. 1992), and Wilson v American Motors Corp., 759 F.2d 1568 (11th Cir. 1985), the Court has requested that we set forth Athe extraordinary circumstances or particularized needs necessitating a

ndard of Rule 26(c) applies. Chicago Tribune Co. v. Bridgestone/Firestone Inc., 263 F.3d 1304, 1310 (I I th Cir. 2001) (AThe district court required Firestone to meet a compelling interest standard. To the extent this was predicated on a constitutional right of access, it was error@). a. Heightened Scrut