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

responsive to this request that are not otherwise protected opinion work product. No production under this request is necessary. 6. Request No. 25—Initial Disclosures under FRCP 26(a)(1) Finally, Petitioners request that the Government comply with its obligation to serve initial disclosures under Federal Rule of

.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

responsive to this request that are not otherwise protected opinion work product. No production under this request is necessary. 6. Request No. 25—Initial Disclosures under FRCP 26(2)(1) Finally. Petitioners request that the Government comply with its obligation to serve initial disclosures under Federal Rule of

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

responsive to this request that are not otherwise protected opinion work product. No production under this request is necessary. 6. Request No. 25—Initial Disclosures under FRCP 26(a)(1) Finally, Petitioners request that the Government comply with its obligation to serve initial disclosures under Federal Rule of

.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

responsive to this request that are not otherwise protected opinion work product. No production under this request is necessary. 6. Request No. 25—Initial Disclosures under FRCP 26(a)(1) Finally, Petitioners request that the Government comply with its obligation to serve initial disclosures under Federal Rule of