Epstein Secrets

is greater than the need for continued secrecy"; and (3) "that their request is structured to cover only material so needed." Id. at 1348 (citing Douglas Oil Co.,N.W., 441 U.S. 211, 222 (1979)). These demanding standards apply even after the grand jury has concluded its operations. Id. The burden of demonstr

opposing parties and their counsel." Hickman I. Taylor, 329 U.S. 495, 510 (1947). The privilege is codi

F.3d at 1347. "The district court has 'substantial discretion' in determining whether grand jury materials should be released." Id. at 1349 (quoting Douglas Oil Co. v. Petrol Stops N.W., 441 U.S. 211, 223, 99 S. Ct. 1667, 60 L. Ed. 2d 156 (1979)). For internal use only SDNY_GM_00059572 CONFIDENTIAL - PURSUANT

y opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510, 67 S. Ct. 385, 91 L. Ed. 451

.3d at 1347. "The district court has `substantial discretion' in determining whether grand jury materials should be released." Id. at 1349 (quoting Douglas Oil Co. v. Petrol Stops N.W., 441 U.S. 211, 223 (1979)). Whether proceeding under Rule 6(e)(3) or the court's inherent authority, there are well 5 EFTA_R1

opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510 (1947). The privilege is codi

The Supreme Court has explained that a party seeking disclosure of grand jury materials must make a showing of a "particularized need." Id. (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 222 (1979)). Petitioners cannot make such a showing. Moreover, the documents they seek to make available

t"); id. at 410 ("Simply put, once a federal court determines that it is without subject matter jurisdiction, the court is powerless to continue."); Taylor v. Appleton, 30 F.3d 1365, 1366 (11th Cir. 1994) ("[A] court must first determine whether it has proper subject matter jurisdiction before addressi

The Supreme Court has explained that a party seeking disclosure of grand jury materials must make a showing of a "particularized need." Id. (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 222 (1979)). Petitioners cannot make such a showing. Moreover, the documents they seek to make available

t"); id. at 410 ("Simply put, once a federal court determines that it is without subject matter jurisdiction, the court is powerless to continue."); Taylor v. Appleton, 30 F.3d 1365, 1366 (11th Cir. 1994) ("[A] court must first determine whether it has proper subject matter jurisdiction before addressi

ed secrecy; and (3) the request is structured to cover only needed materials. United States v. Moussaoui, 483 F.3d 220, 235 (4th Cir. 2007) (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 222 (1979)). 20. Portions of Exhibits 1, 2, and 3 are relevant to a judicial proceeding, that is, the Ja

opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510 (1947). The privilege is codi

The Supreme Court has explained that a party seeking disclosure of grand jury materials must make a showing of a "particularized need." Id. (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 222 (1979)). Petitioners cannot make such a showing. Moreover, the documents they seek to make available

t"); id. at 410 ("Simply put, once a federal court determines that it is without subject matter jurisdiction, the court is powerless to continue."); Taylor v. Appleton, 30 F.3d 1365, 1366 (11th Cir. 1994) ("[A] court must first determine whether it has proper subject matter jurisdiction before addressi

.3d at 1347. "The district court has 'substantial discretion' in determining whether grand jury materials should be released." Id. at 1349 (quoting Douglas Oil Co. v. Petrol Stops N.W., 441 U.S. 211, 223 (1979)). Whether proceeding under Rule 6(e)(3) or the court's inherent authority, there are well 5 EFTA016

opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510 (1947). The privilege is codi

einger, 626 F. Supp. 2d 1231 (S.D. Fl. 2009): "The proper functioning of our grand iury system depends upon the secrecy of grand jury proceedings," Douglas Oil Co. Petrol Stops Northwest, 441 U.S. 211, 218 (1979), and this expectation of privacy is generally codified in Rule 6(e) of the Federal Rules of Crimi

ion.' United States' Nobles, 422 U.S. 225, 238 (1975). The work-product doctrine applies in civil and criminal litigation. Id. at 236. In Hickman' Taylor, the Supreme Court described the policy behind the doctrine protecting the opinion work-product of lawyers. The Court explained that a lawyer is bou

The Supreme Court has explained that a party seeking disclosure of grand jury materials must make a showing of a "particularized need." Id. (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 222 (1979)). Petitioners cannot make such a showing. Moreover, the documents they seek to make available

t"); id. at 410 ("Simply put, once a federal court determines that it is without subject matter jurisdiction, the court is powerless to continue."); Taylor v. Appleton, 30 F.3d 1365, 1366 (I I th Cir. 1994) ("[A] court must first determine whether it has proper subject matter jurisdiction before addres