Epstein Secrets

it have applied a balancing test to evaluate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access t

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mono Building One Saint Andrew's Plaza New York. New York 10007 February 28, 2019 TO BE FILED UNDER SEAL VIA EMAIL T

ause, we respectfully submit, improperly gives short shrift to the parties' and non-parties' reliance on the district court's protective order. "In Martindell v. International Telephone & Telegraph Corp., 594 F.2d 291 (2d Cir. 1979), this Court established a strong presumption against access to sealed doc

rsons: The Hon. Robert W. Sweet Paul G. Cassell District Judge ([email protected]) United States District Court for the Sigrid S. McCawley Southern District of New York ([email protected]) (via United States mail) Christine N. Walz ([email protected]) Madelaine J. Harrington (madelaine.har

it have applied a balancing test to evaluate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access t

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 February 28, 2019 TO BE FILED UNDER SEAL VIA EMAIL

it have applied a balancing test to evaluate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access t

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mediu Building One Saint Andrew's Plaza New York. New York 10007 February 28, 2019 TO BE FILED UNDER SEAL VIA EMAIL

ondaga, 435 F.3d 110 (2d Cir. 2006) 19, 21 Maldanado v. City of New York, Case No. 17-cv-6618 (AJN), 2018 WL 2561026 (S.D.N.Y. June 1, 2018) 35 Martindell v. Int'l Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979) passim N.Y. Civil Liberties Union v. N.Y.C. Transit Auth. (NYCTA), 684 F.3d 286 (2d Cir. 2

cord. I also certify that I mailed a copy of the opening brief to: The Hon. Loretta A. Preska District Judge United States District Court for the Southern District of New York (via United States mail) s/ Nicole Simmons 43 EFTA00075525 Case 20-2413, Document 40. 08/20/2020. 2913550. Page50 of 74 Attachment

it have applied a balancing test to evaluate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access t

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mediu Building One Saint Andrew's Plaza New York. New York 10007 February 28, 2019 TO BE FILED UNDER SEAL VIA EMAIL

So I can't speak to why Boies Schiller in particular didn't make their own application. THE COURT: Because I understand that you don't think that Martindell is applicable here, but I do, and now I'm the judge. I wish I weren't. You know that the Second Circuit has SOUTHERN DISTRICT REPORTERS, P.C. (212

e New York, N.Y. March 26, 2019 4:04 p.m. HON. COLLEEN McMAHON, District Judge APPEARANCES GEOFFREY S. BERMAN United States Attorney for the Southern District of New York BY: Assistant United States Attorney SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 SDNY_ GM_ 00000&53 EFTA00084766 2 Xj3q1gra

to normalize, without citation to authority, its conduct as "standard practice." Resp. at 2. To the contrary, the controlling case in this Circuit, Martindell v. Intl Telephone & Telegraph Corp., 594 F.2d 291, 293 (2d Cir. 1979), mandates a wholly different procedure: the use of a non-ex pane subpoena wit

Paglluca II A D D O N M OR G A N FOREMAN 303.832.2628 August 24, 2020 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York Re: Reply in Support of Request to Modify Protective Order (Under Seal)i United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judg

2016 depositions, both of which were designated "Confidential." Two, the government had no ability legally to obtain the deposition transcripts. In Martindell v. International Telephone and Telegraph Corp., 594 F.2d 291, 293 (2d Cir. 1979), cited with approval in In re Teligent, Inc., 640 F.3d 53, 58 (2d

7433-LAP Document 1078 Filed 07/29/20 Page 1 of 9 HADDON MORGAN FOREMAN July 29, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, r.0 Ty Gee 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.

Obtained in Violation of the Sixth Amendment 10. Motion for a Bill of Particulars and Pretrial Disclosures II. Motion Under the Fourth Amendment, Martindell, and the Fifth Amendment to Suppress All Evidence Obtained from the Government's Subpoena to and to Dismiss Counts Five and Six 12. Motion to Dism

022 Mark S. Cohen Christian R. Eveniell +1 1212 957-7600 January 25, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) www.00hengeSSer.COM Dear Judge Nat