Epstein Secrets

sarily jeopardize the privacy and reputational interests of the named individuals. United States v. Smith, 776 F.2d 1104, 1114 (3d Cir. 1985); cf. Douglas Oil Co. of Ca. v. Petrol Stops NW, 441 U.S. 211, 219 (1979) (observing that grand jury secrecy is designed in part to "assure that persons who are accused

of 13 TABLE OF AUTHORITIES Cases Bernstein v. Bernstein Litowitz Berger & Grossman LLP, 814 F.3d 132 (2d Cir. 2016) 7 Douglas Oil Co. of Ca. v. Petrol Stops NW, 441 U.S. 211 (1979) 7 Gardner v. Newsday, Inc., 895 F.2d 74 (2d Cir. 1990) 5 In re New York Times Co., 828 F.2d 110 (2d Cir. 1987) 4, 5, 8

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

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 TO FED. R.QQN(F

er the Fourth and Fifth Amendments (Motion II) are narrowly tailored to protect the integrity of the Government's ongoing investigation. See, e.g., Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 218 n.9 (1979) ("Since the 17th century, grand jury proceedings have been closed to the public; and record

Fifth Amendments (Motion II) are narrowly tailored to protect the integrity of the Government's ongoing investigation. See, e.g., Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 218 n.9 (1979) ("Since the 17th century, grand jury proceedings have been closed to the public; and records of such procee