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

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 The Honorable Robert W. Sweet United States District Court Southern District of New York United States Courthouse New York, New York 10007 Re: In re Application to Unseal Ci

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

Street, Salt Lake City, UT 84112-0730 303.831.7364; [email protected] 801.585.5202; [email protected] Court- Judge/ Agency appealed from: Hon. Robert W. Sweet, District Judge (S.D.N.Y.) Please check appropriate boxes: Has movant notified posing counsel (required by Local Rule 27.1): {} Yes No (explain)

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

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 The Honorable Robert W. Sweet United States District Court Southern District of New York United States Courthouse New York, New York 10007 Re: In re Application to Unseal Ci

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

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 The Honorable Robert W. Sweet United States District Court Southern District of New York United States Courthouse New York, New York 10007 Re: In re Application to Unseal Ci

74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Applicable Law 76 b. Discussion 79 2. Maxwell's Fourth Amendment Claim Fails 8

moved for an entry of a protective order for materials produced in discovery and submitted a proposed order for the consideration of the Honorable Robert W. Sweet, the United States District Judge who was then overseeing the Giu&•e v. Maxwell civil litigation. (See 15 Civ. 7433 (LAP), Dkt. Nos. 38 & 39-1). On