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

even if the communications themselves are not privileged. See Charles E. Hill & Associates, Inc. v. ABT Electronics, Inc., 854 F. Supp. 2d 427, 430 (E.D. Tex. 2012) (designating discovery material including settlement communications as "Outside Counsel Eyes Only Confidential Information" and cautioning pa

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

even if the communications themselves are not privileged. See Charles E. Hill & Associates, Inc. g ABT Electronics, Inc., 854 F. Supp. 2d 427, 430 (E.D. Tex. 2012) (designating discovery material including settlement communications as "Outside Counsel Eyes Only Confidential Information" and cautioning pa

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

to chill settlement efforts) (citations omitted). 14 EFTA00582800 Charles E Associates, Inc. v. ART Electronics, Inc, 854 F. Supp. 2d 427, 430 (E.D. Tex. 2012) (designating discovery material including settlement communications as AOutside Counsel Eyes Only Confidential Information@ and cautioning pa