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atively limited, due to the confidential nature" of the litigation. (Id. at 2 n.1). The Government also submitted that the court need not employ the Manindell balancing test to evaluate the Government's ability to obtain access to materials covered by a protective order because (1) the Martindell balancin
1977) 187 United States v. Aleman, 286 F.3d 86 (2d Cir. 2002) 27 United States v. Alfonso, 143 F.3d 772 (2d. Cir. 1998) 226 United States v. Amato, 15 F.3d 230 (2d Cir. 1994) 209 United States v. An Antique Platter of Gold, 184 F.3d 131 (2d Cir. 1999) 222 United States v. Anderson, 747 F.
fy Rule 26(c) protective orders that precluded full compliance with those subpoenas. While the Government argued that the court need not employ the Manindell balancing test for several reasons, it also made arguments under Martindell in the alternative. Ultimately, both Chief Judge McMahon and Judge Netbu
use Rule 8(a) already strikes a "balance" between "considerations of economy and speed" and "possible unfairness" to the defendant. United States v. Amato, 15 F.3d 230, 237 (2d Cir. 1994). Accordingly, "the principles that guide the district court's consideration of a motion for severance usually coun
fy Rule 26(c) protective orders that precluded full compliance with those subpoenas. While the Government argued that the court need not employ the Manindell balancing test for several reasons, it also made arguments under Martindell in the alternative. Ultimately, both Chief Judge McMahon and Judge Netbu
use Rule 8(a) already strikes a "balance" between "considerations of economy and speed" and "possible unfairness" to the defendant. United States v. Amato, 15 F.3d 230, 237 (2d Cir. 1994). Accordingly, "the principles that guide the district court's consideration of a motion for severance usually coun
Entities connected to both Manindell and Amato

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
United States
LOCATIONSubpoena Duces
PERSONthe Southern District
LOCATIONMaria Farmer
PERSON
David Boies
PERSON
Julie K. Brown
PERSONSweet
PERSON
Carpenter
PERSONColleen McMahon
PERSONStokes
PERSONMason
ORGANIZATION
Heath
PERSON
George Mitchell
PERSONFisher
PERSON
Supreme Court
ORGANIZATIONTowne
LOCATIONVilar
PERSON
Adriana Ross
PERSON