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

nduct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g. In re Sealed Case 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar mis

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

e level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401, 244 U.S. App. D.C. 11 (D.C. Cir. 1985) (exception to attorney- client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar mis

.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

uct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar mis

re of grand jury materials must make a showing of a "particularized need." United States v. Aisenberg, 358 F.3d 1327, 1348 (11th Cir. 2004) (citing Douglas Oil Co. a Petrol 27 EFTA00085735 Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 28 of 32 Stops Northwest, 441 U.S. 211, 222

ed, but simply forgot, to provide additional remedies beyond those already specified. Courts agree. See United States v. Monzel, 641 F.3d 528, 542 (D.C. Cir. 2011) (holding that the CVRA's "carefully crafted and detailed enforcement scheme," provides "strong evidence that Congress did not intend to auth

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

uct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar mis

.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

nduct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g. In re Sealed Case 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar mis