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the investigation if the facts are known or might attempt to escape if they have reason to believe certain indictments will issue. United States v. Eisenberg, 711 F.2d 959, 961 (11th Cir. 1983) (citing United States v. Procter & Gamble Co., 356 U.S. 677, 681 n.6 (1958)). Several of the "facts" contained
10 of access is not absolute and sealing is appropriate in connection with grand jury proceedings. As explained by Judge Jordan in United States v. Steinger, 626 F. Supp. 2d 1231 (S.D. Fl. 2009): "The proper functioning of our grand jury system depends upon the secrecy of grand jury proceedings," Dougla
the investigation if the facts are known or might attempt to escape if they have reason to believe certain indictments will issue. United States I Eisenberg , 711 F.2d 959, 961 (11th Cir. 1983) (citing United States I Procter & Gamble Co. , 356 U.S. 677, 681 n.6 (1958)). EFTA00208547 Several of the "f
Court , 464 U.S. 501 (1984)] so as to warrant sealing, and provides good cause under the common-law access balancing test to preclude disclosure. Steinger , 626 F. Supp. 2d at 1235-36 (brackets in original omitted). See also In re Petition of American Historical Ass 'n , 62 F. Supp. 2d 1100, 1103 (S.D
the investigation if the facts are known or might attempt to escape if they have reason to believe certain indictments will issue. United States v. Eisenberg , 711 F.2d 959, 961 (11th Cir. 1983) (citing United States v. Procter & Gamble Co. , 356 U.S. 677, 681 n.6 (1958)). EFTA00208554 Several of the "
ght of access is not absolute and sealing is appropriate in connection with grand jury proceedings. As explained by Judge Jordan in United States v. Steinger , 626 F. Supp. 2d 1231 (S.D. Fl. 2009): "The proper functioning of our grand jury system depends upon the secrecy of grand jury proceedings," Doug
the investigation if the facts are known or might attempt to escape if they have reason to believe certain indictments will issue. United States I Eisenberg , 711 F.2d 959, 961 (11th Cir. 1983) (citing United States I Procter & Gamble Co. , 356 U.S. 677, 681 n.6 (1958)). Several of the "facts" contained
Court , 464 U.S. 501 (1984)] so as to warrant sealing, and provides good cause under the common-law access balancing test to preclude disclosure. Steinger , 626 F. Supp. 2d at 1235-36 (brackets in original omitted). See also In re Petition of American Historical Ass 'n , 62 F. Supp. 2d 1100, 1103 (S.D
and jury will not be held up to public ridicule." a at 218-19; see United States v. John Doe Inc. I, 481 U.S. 102, 109 n.5 (1987); United States v. Eisenberg, 711 F.2d 959, 961 (11th Cir. 1983); Lance v. United States Dep't of Justice (In re Grand Jury Investigation), 610 F.2d 202, 213 (5th Cir. 1980). A
ly entitled to protection, as there may have been accusations made for which no indictment was returned." Id. at 218 n.8; see also United States v. Steinger, No. 08-21158-CR, 2009 WL 1674798, at *3 (S.D. Fla. Apr. 28, 2009) (discussing the "devastating consequences" from revealing names of "those person
the investigation if the facts are known or might attempt to escape if they have reason to believe certain indictments will issue. United States v. Eisenberg, 711 F.2d 959, 961 (11th Cir. 1983) (citing United States v. Procter & Gamble Co., 356 U.S. 677, 681 n.6 (1958)). Several of the "facts" contained
10 of access is not absolute and sealing is appropriate in connection with grand jury proceedings. As explained by Judge Jordan in United States v. Steinger, 626 F. Supp. 24i 1231 (S.D. Fl. 2009): "The proper functioning of our grand jury system depends upon the secrecy of grand jury proceedings," Dougl
the investigation if the facts are known or might attempt to escape if they have reason to believe certain indictments will issue. United States. Eisenberg, 711 F.2d 959, 961 (11th Cir. 1983) (citing United States. Procter & Gamble Co., 356 U.S. 677, 681 n.6 (1958)). Several of the "facts" contained in
cy seeks to protect . . unindicted individuals from the anxiety, embarrassment, and public castigation that may result from disclosure.") (cited in Steinger). 5 08-80736-CV-MARRA 000941 EFTA00230765 e•;;S",:%%::: - - • /len" Case 9:08-cv-80736-KAM Document 60 Entered on FLSD Docket 04/07/2011 Pag
the investigation if the facts arc known or might attempt to escape if they have reason to believe certain indictments will issue. United States v. Eisenberg, 711 F.2d 959, 961 (11th Cir. 1983) (citing United States v. Procter & Gamble Co., 356 U.S. 677, 681 n.6 (1958)). Several of the "facts" contained
r Court, 464 U.S. 501 (1984)] so as to warrant scaling, and provides good cause under the common-law access balancing test to preclude disclosure. Steinger, 626 F. Supp. 2d at 1235-36 (brackets in original omitted). See also In re Petition of American Historical Assn, 62 F. Supp. 2d 1100, 1103 (S.D.N.Y.
Entities connected to both James Eisenberg and Steinger

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Kenneth Marra
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Bradley Edwards
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Scarlett Johansson
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