Epstein Secrets

by the corporations which are defendants in the civil case, the considerations . . . militating against disclosure are beside the point.") (citing Douglas Oil Co. of Calif. v. Petrol Stops Nw., 441 U.S. 211 (1979)). In response to such third-party subpoenas to law-enforcement witnesses, we anticipate that it

ON OF • CERTAIN AS9STAhrE Kass CONTACT Lww JAFFE. ADA COORDIVEDE IN TIC ACEANSMATHE awe CHIT COM PAW BEACH MOEN ECWRFICEISM 205 N EWE I'MT, RE SSA WEST PALM MACK FL MEN: TUB:HONE (561)6%.4150, WWI a ME NNE ONS Of YOUR Rear OF THE NONCE. IF YOU AM HEARING OR VOCE IMPAIRED, CALL 14304554Th. — , Form 6)1 E

e 6(e) remains non-public, thus effectuating the privacy concerns addressed by the United States Supreme Court in Douglas and other cases. See e.g. Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 228-30 (1979). Under Rule 6(e), only a federal court can, absent findings, order the unsealing of federal

205 North Dixie Highway Room 11F West Palm Beach, FL 33401 ROBERT D. CRITTON BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm 33401 and JACK A. GOLDBERGER ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 allir3eac 3401 and JANE KREUSLER-WAL

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

on for Permission to Disclose Grand Jury Material" for the following reasons: 1. The Application contains information regarding proceedings before West Palm Beach Federal Grand Jury 07-103, which is subject to the secrecy protections of Fed. R. Crim. P. 6. 2. Pursuant to Rule 6(eX6), "[r]ecords, orders,

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

80736-Civ-Marra, and any dissemination of such grand jury information shall be accompanied by a copy of this Order. DONE AND ORDERED in Chambers at West Palm Florida, this 7" day of November, 2011. DUDIICLD M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE 2 DatE EFTA00081053 Case 9:08-cv-80736-KAM Do

by the corporations which are defendants in the civil case, the considerations . . . militating against disclosure are beside the point.") (citing Douglas Oil Co. of Calif, Petrol Stops Nw., 441 U.S. 211 (1979)). In response to such third-party subpoenas to law-enforcement witnesses, we anticipate that it wi

n FLSD Docket 07/15/200 %ay U.S. Department of Justice United States Attorney Southern District of Florida 500 Sough Australian Arc.. Suite 400 West Palm !leach. Ft 53401 (5611820.87 I Facsimile August 11, 2006 Re: Crime Vicijins' and Witnesses' Ruth's Dear Miss a Pursuant to the Justice for All

by the corporations which are defendants in the civil case, the considerations . . . militating against disclosure are beside the point.") (citing Douglas Oil Co. of Calif Petrol Stops Nw., 441 U.S. 211 (1979)). In response to such third-party subpoenas to law-enforcement witnesses, we anticipate that it will

EFTA00175593 • CM/ECF - Live Database - flsd Page 6 of 21 Michael James Pike Burman Critton Luttier & Coleman 515 N Flagler Drive Suite 400 West Palm each , FL 33401-2918 Fax: 515-3148 Email: ATTORNEY TO BE NOTICED Michael Ross Tein Lewis Tein 3059 Grand Avenue Suite 340 Coconut e , FL 331

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

80736-Civ-Marra, and any dissemination of such grand jury information shall be accompanied by a copy of this Order. DONE AND ORDERED in Chambers at West Palm Florida, this 7 day of November, 2011. DONICLD M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE 2 EFTA00208860 Exhibit A EFTA00208861 IN THE