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order exists. See In re Grand Jury Subpoena, 836 F.2d 1468, 1477 (4th Cir.), cert. denied, 487 U.S. 1240 (1988); In re Grand Jury Subpoena Served on Meserve, Mumper & Hughes, 62 F.3d 1222, 1226-1227 (9th Cir. 1995); In re Grand Jury Proceedings (Williams), 995 F.2d 1013, 1020 (11th Cir. 1993) (expressly criticizing the
had at least called the witness before the grand jury). The subject matter of the Litigation also demonstrates the extraordinary circumstances of the Government's Investigation and Application, insofar as the materials at issue here appear not to be of the sort that ordinarily would provide protection against Government investigation. See
order exists. See In re Grand Jury Subpoena, 836 F.2d 1468, 1477 (4th Cir.), cert. denied, 487 U.S. 1240 (1988); In re Grand Jury Subpoena Served on Meserve, Mumper & Hughes, 62 F.3d 1222, 1226-1227 (9th Cir. 1995); In re Grand Jury Proceedings (Williams), 995 F.2d 1013, 1020 (11th Cir. 1993) (expressly criticizing the
had at least called the witness before the grand jury). The subject matter of the Litigation also demonstrates the extraordinary circumstances of the Government's Investigation and Application, insofar as the materials at issue here appear not to be of the sort that ordinarily would provide protection against Government investigation. See
order exists. See In re Grand Jury Subpoena, 836 F.2d 1468, 1477 (4th Cir.), cert. denied, 487 U.S. 1240 (1988); In re Grand Jury Subpoena Served on Meserve, Mumper & Hughes, 62 F.3d 1222, 1226-1227 (9th Cir. 1995); In re Grand Jury Proceedings (Williams), 995 F.2d 1013, 1020 (11th Cir. 1993) (expressly criticizing the
had at least called the witness before the grand jury). The subject matter of the Litigation also demonstrates the extraordinary circumstances of the Government's Investigation and Application, insofar as the materials at issue here appear not to be of the sort that ordinarily would provide protection against Government investigation. See
order exists. See In re Grand Jury Subpoena, 836 F.2d 1468, 1477 (4th Cir.), cert. denied, 487 U.S. 1240 (1988); In re Grand Jury Subpoena Served on Meserve, Mumper & Hughes, 62 F.3d 1222, 1226-1227 (9th Cir. 1995); In re Grand Jury Proceedings (Williams), 995 F.2d 1013, 1020 (11th Cir. 1993) (expressly criticizing the
had at least called the witness before the grand jury). The subject matter of the Litigation also demonstrates the extraordinary circumstances of the Government's Investigation and Application, insofar as the materials at issue here appear not to be of the sort that ordinarily would provide protection against Government investigation. See
Entities connected to both Meserve, Mumper & Hughes and the Government's Investigation and Application

Jeffrey Epstein
PERSON
Prince Andrew
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David Boies
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ORGANIZATIONChemical Bank
ORGANIZATIONMartindell
PERSONBranzburg v. Hayes
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Orange
LOCATIONJ. Gorenstein
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Department of Justice
ORGANIZATIONRoach
PERSONthe Protective Order
ORGANIZATIONInternational Tel
ORGANIZATIONSouthern District
LOCATIONthe Federal Criminal Code
ORGANIZATIONFourt
ORGANIZATIONTeL Corp.
ORGANIZATIONEleventh Circuits
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Woody Allen
PERSON
Boies Schiller & Flexner LLP
ORGANIZATION