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ed to the court, the filing "shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York." (Id. ¶ 10.) The docket sheet in v. Maxwell reveals that such motions were frequently made and routinely granted. As a result, a vast
r by the Plaintiff or her lawyers." (Def.'s Reply in Further Supp. of Mot. for Protective Order, 15-cv-7433, Dkt. No. 49 at 5); cf. Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 743 (2d Cir. 1987) ("[O]ne of the primary reasons the protective order was originally entered was to prevent plaintiffs from u
ial settlement agreement. Early in the civil litigation, one of the attorneys representing_approached an Assistant United States Attorney (AUSA) in the Southern District of New York and requested a EFTA00040664 meeting to provide the Government information on possible criminal conduct. The AUSA met with three atto
independent basis to modify a protective order under Martindell notwithstanding the parties' reasonable reliance on that order. See Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 742 (2d Cir. 1987) (citing Martindell, 594 F.2d at 296). Thus, even assuming that the Government should have told Judge McMah
al settlement agreement. Early in the civil litigation, one of the attorneys representing approached an Assistant United States Attorney (AUSA) in the Southern District of New York and requested a No. EFTA00106039 Case 1:20-cr-00330-AJN Document 307 Filed 06/25/21 Page 2 of 21 meeting to provide the Government i
independent basis to modify a protective order under Martindell notwithstanding the parties' reasonable reliance on that order. See Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 742 (2d Cir. 1987) (citing Martindell, 594 F.2d at 296). Thus, even assuming that the Government should have told Judge McMah
al settlement agreement. Early in the civil litigation, one of the attorneys representing approached an Assistant United States Attorney (AUSA) in the Southern District of New York and requested a EFTA00066510 meeting to provide the Government information on possible criminal conduct. The AUSA met with three atto
independent basis to modify a protective order under Martindell notwithstanding the parties' reasonable reliance on that order. See Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 742 (2d Cir. 1987) (citing Martindell, 594 F.2d at 296). Thus, even assuming that the Government should have told Judge McMah
ed to the court, the filing "shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York." (Id ¶ 10.) The docket sheet in Giulfre v. Maxwell reveals that such motions were frequently made and routinely granted. As a result,
tor by the Plaintiff or her lawyers." (Def's Reply in Further Supp. of Mot. for Protective Order, 15-cv-7433, Dkt. No. 49 at 5); of Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 743 (2d Cir. 1987) ("[O]ne of the primary reasons the protective order was originally entered was to prevent plaintiffs from u
al settlement agreement. Early in the civil litigation, one of the attorneys representing approached an Assistant United States Attorney (AUSA) in the Southern District of New York and requested a EFTA00087251 meeting to provide the Government information on possible criminal conduct. The AUSA met with three atto
independent basis to modify a protective order under Martindell notwithstanding the parties' reasonable reliance on that order. See Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 742 (2d Cir. 1987) (citing Martindell, 594 F.2d at 296). Thus, even assuming that the Government should have told Judge McMah
al settlement agreement. Early in the civil litigation, one of the attorneys representing approached an Assistant United States Attorney (AUSA) in the Southern District of New York and requested a EFTA00087230 meeting to provide the Government information on possible criminal conduct. The AUSA met with three atto
independent basis to modify a protective order under Martindell notwithstanding the parties' reasonable reliance on that order. See Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 742 (2d Cir. 1987) (citing Martindell, 594 F.2d at 296). Thus, even assuming that the Government should have told Judge McMah
Entities connected to both the Southern District and Conticommodity Servs

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Southern District of New York
ORGANIZATION
Donald Trump
PERSON
Julie K. Brown
PERSON
Supreme Court
ORGANIZATION
David Boies
PERSONSecond Circuit
ORGANIZATION
Woody Allen
PERSON
Robert Gates
PERSONFisher
PERSONColleen McMahon
PERSON
Eric Schmidt
PERSONSalameh
PERSON
ALISON J. NATHAN
ORGANIZATION
Carpenter
PERSONMartindell
PERSONthe Second Circuit's
ORGANIZATION