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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
e a sufficient, 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 shoul
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
e a sufficient, 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 shoul
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
e a sufficient, 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 shoul
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
e a sufficient, 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 shoul
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
e a sufficient, 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 shoul
Entities connected to both the Southern District and Minpeco S.A.

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
Supreme Court
ORGANIZATION
David Boies
PERSONSecond Circuit
ORGANIZATIONJeffrey Pagliuca
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Robert Gates
PERSONFisher
PERSONColleen McMahon
PERSONSalameh
PERSON
Eric Schmidt
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ALISON J. NATHAN
ORGANIZATION
Carpenter
PERSONMartindell
PERSONthe Second Circuit's
ORGANIZATIONUSDC SONY
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Boies Schiller
ORGANIZATIONAndover Data Servs
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