Epstein Secrets

rotective order"); H.L. Hayden Co. of New York v. Siemens Med Sys., Inc., 797 F.2d 85, 90 (2d Cir. 1986) ("[W]e continue to adhere to our holding in Martindell [v. International Tel. and Tel. Corp., 594 F.2d 291, 294 (2d Cir. 1979)), that 'this extraordinary writ [mandamus] would hardly be available . . .

rial during the course of the litigation on the understanding that it will be kept confidential—for example, by .. . giving confidential testimony." Allen v. City of N.Y., 420 F. Supp. 2d 295, 300-01 (S.D.N.Y. 2006). The record shows that likely could not have secured Maxwell's deposition—at least in the abs

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

f the litigation."). But this is not a case where the "conditions contemplated by the Court for revisiting the Protective Order have now occurred." Allen v. City of N.Y. 420 F. Supp. 2d 295, 301 (S.D.N.Y. 2006). All parties to the Protective Order have not been given notice and an opportunity to be heard. See

otective order."); H.L. Hayden Co. of New York v. Siemens Med Sys., Inc., 797 F.2d 85, 90 (2d Cir. 1986) ("[W]e continue to adhere to our holding in Martindell [v. International Tel. and Tel. Corp., 594 F.2d 291, 294 (2d Cir. 1979)], that `this extraordinary writ [mandamus] would hardly be available ... wh

rial during the course of the litigation on the understanding that it will be kept confidential—for example, by .. . giving confidential testimony." Allen v. City of N.Y., 420 F. Supp. 2d 295, 300-01 (S.D.N.Y. 2006). The record shows that Giuffre likely could not have secured Maxwell's deposition—at least in