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

be negated because the Government's communications facilitated "misconduct" by depriving the victims of their rights under the CVRA. (DE 265 at 6). The Eleventh Circuit has recognized that "[t]he crime-fraud exception presents one of the rare and extraordinary circumstances in which 15 EFTA00210154 Case 9:08-cv-

.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

be negated because the Government's communications facilitated "misconduct" by depriving the victims of their rights under the CVRA. (DE 265 at 6). The Eleventh Circuit has recognized that "[t]he crime-fraud exception presents one of the rare and extraordinary circumstances in which 15 EFTA_R1_01293450 EFTA023359

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

intentions, partial rescission would pose a significant risk of harm to certain victims, which must be considered in crafting an equitable remedy. The Eleventh Circuit has admonished courts considering equitable remedies to "bear in mind that a poorly crafted remedy may achieve justice for one by working a substan

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

be negated because the Government's communications facilitated "misconduct" by depriving the victims of their rights under the CVRA. (DE 265 at 6). The Eleventh Circuit has recognized that "[t]he crime-fraud exception presents one of the rare and extraordinary circumstances in which 15 EFTA00086459 Case 9:08-cv-

.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

be negated because the Government's communications facilitated "misconduct" by depriving the victims of their rights under the CVRA. (DE 265 at 6). The Eleventh Circuit has recognized that "[t]he crime-fraud exception presents one of the rare and extraordinary circumstances in which 15 EFTA01657766 Case 9:08-cv-

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

s confidential, and accordingly they should be made part of the Court's public file. In addition, no sealing order could be justified in this case. The Eleventh Circuit has instructed that the district courts must make substantial findings before sealing records in cases before it. For instance, in United States' O