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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
s in the possession of Boies Schiller & Flexner LLP (the "A in connection with the matter v. Ghislaine Maxwell, et at (a"), 15 Civ. 7433 (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the Government has served a grand jury subpoena (the "Subp
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
in the possession of Boies Schiller & Flexner LLP (the "A in connection with the matter v. Ghislaine Maxwell, et al. ("M"), 15 Civ. 7433 (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the Government has served a grand jury subpoena (the "Subp
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
covery materials in the possession of Boies Schiller & Flexner LLP the "A in connection with the matter v. Ghislaine Maxwell, et al. (a), (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the Government has served a grand jury subpoena (the "Subp
Entities connected to both Martindell and the "Litigation"

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSONSweet
PERSONthe Southern District
LOCATION
United States
LOCATION
Boies Schiller
ORGANIZATION
Bradley Edwards
PERSONJane Doe
PERSONChemical Bank
ORGANIZATION
Prince Andrew
PERSONSubpoena Duces
PERSON
George W. Bush
PERSONSouthern District
LOCATIONSigrid McCawley
PERSONBranzburg v. Hayes
PERSON
Department of Justice
ORGANIZATIONDarren Indyke
PERSONInternational Tel
ORGANIZATION
Woody Allen
PERSON