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has established exceptional circumstances or a compelling need. In re Grand Jury Subpoena Duces Tecum 945 F.2d 1221, 1224 (2d Cir. 1991)• see also Martindell v. International Tel. and Tel. Corp., 594 F.2d 291 (2d Cir. 1979). Because the Government does not argue that the Protective Order was improvidentl
tion. For instance, protective orders that are on their face temporary or limited may not justify reliance by the parties."); see also In re "Agent Orange" Prod. Liab. Litig., 821 F.2d 139, 147 (2d Cir. 1987) ("[A]ppellants . . could not have relied on the permanence of the protective order. The .. . order b
e, and the Court's inherent authority. However, Maxwell's motion turns on erroneous facts, runs afoul of controlling law, and should be denied. 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks Maxwell argues that the Government "circumvented" the Second Circuit's decision in Martin
to modification," and a decision to modify such an order is "committed to the sound discretion of the trial court." ha re 76 EFTA00100043 "Agent Orange" Prod. Liab. Litig., 821 F.2d 139, 147 (2d Cir. 1987); see also Andover Data Servs., a Div. of Players Computer, Inc. v. Statistical Tabulating Corp., 876
overnment's arguments for exceptional circumstances and compelling need as relying on "the general desire for secrecy" and "unpersuasive" under the Martindell standard. (Id. at 6). Judge Netbum concluded that "the Government must demonstrate not that this investigation is an extraordinary circumstance, but
to modification," and a decision to modify such an order is "committed to the sound discretion of the trial court." In re 76 EFTA00077708 "Agent Orange" Prod. Liab. Litig., 821 F.2d 139, 147 (2d Cir. 1987); see also Andover Data Sows., a Div. of Players Computer, Inc. v. Statistical Tabulating Corp., 876 F
overnment's arguments for exceptional circumstances and compelling need as relying on "the general desire for secrecy" and "unpersuasive" under the Martindell standard. (Id. at 6). Judge Netbum concluded that "the Government must demonstrate not that this investigation is an extraordinary circumstance, but
to modification," and a decision to modify such an order is "committed to the sound discretion of the trial court." In re 76 EFTA00039523 "Agent Orange" Prod. Liab. Litig., 821 F.2d 139, 147 (2d Cir. 1987); see also Andover Data Sows., a Div. of Players Computer, Inc. v. Statistical Tabulating Corp., 876 F
uppression Motion Should Be Denied Maxwell seeks suppression of the evidence the Government obtained via a judicially authorized subpoena to under Martindell, the Fourth Amendment, Fifth Amendment, the Due Process clause, and the Court's inherent authority. However, Maxwell's motion turns on erroneous fa
e order is subject to modification," and a decision to modify such an order is "committed to the sound discretion of the trial court." In re "Agent Orange" Prod. Liab. Litig., 821 F.2d 139, 147 (2d Cir. 1987); see also Andover Data Servs., a Div. of Players Computer, Inc. v. Statistical Tabulating Corp., 876
overnment's arguments for exceptional circumstances and compelling need as relying on "the general desire for secrecy" and "unpersuasive" under the Martindell standard. (Id. at 6). Judge Netburn concluded that "the Government must demonstrate not that this investigation is an extraordinary circumstance, bu
to modification," and a decision to modify such an order is "committed to the sound discretion of the trial court." In re 76 EFTA00103101 "Agent Orange" Prod. Liab. Litig., 821 F.2d 139, 147 (2d Cir. 1987); see also Andover Data Sows., a Div. of Players Computer, Inc. v. Statistical Tabulating Corp., 876 F
Entities connected to both Martindell and Orange" Prod.

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
Julie K. Brown
PERSONColleen McMahon
PERSONSweet
PERSON
United States
LOCATIONthe Southern District
LOCATIONJane Doe
PERSON
Southern District of New York
ORGANIZATIONthe Second Circuit's
ORGANIZATIONFisher
PERSONLoretta A. Preska
PERSON
Bradley Edwards
PERSON
Colorado
LOCATIONJeffrey Pagliuca
PERSON
Eric Schmidt
PERSON
Carpenter
PERSON
Supreme Court
ORGANIZATION
Virginia Giuffre
PERSON