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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
United States v. Countentos, 651 F.3d 809 (8th Cir. 2011) 57, 58 United States v. Cromitie, 727 F.3d 194 (2d Cir. 2019) 154 United States v. Cromitie, et al., 09 Cr. 558 (CM) 286 United States v. &ouch, 84 F.3d 1497 (5th Cir. 1996) 75 United States v. DAtnico, 734 F. Supp. 2d 321 (S.D.N.Y. 2
v. Corr, 543 F.2d 1042 (2d Cir. 1976) 181 xii EFTA00099953 United States v. Countentos, 651 F.3d 809 (8th Cir. 2011) 57, 58 United States v. Cromitie, 727 F.3d 194 (2d Cir. 2019) 154 United States v. Cromitie, et al., 09 Cr. 558 (CM) 286 United States v. &ouch, 84 F.3d 1497 (5th Cir. 1996)
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
guarantees of due process." United States v. Heyward, No. 10 Cr. 84 (LTS), 2010 WL 4484642, at *3 (S.D.N.Y. Nov. 9, 2010); see also United States v. Cromitie, 727 F.3d 194, 218 (2d Cir. 2019). There also "must be a causal connection between the violation and the deprivation of the defendant's life or li
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
guarantees of due process." United States v. Heyward, No. 10 Cr. 84 (LTS), 2010 WL 4484642, at *3 (S.D.N.Y. Nov. 9, 2010); see also United States v. Cromitie, 727 F.3d 194, 218 (2d Cir. 2019). There also "must be a causal connection between the violation and the deprivation of the defendant's life or li
Entities connected to both Manindell and Cromitie

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONColleen McMahon
PERSON
Bill Richardson
PERSON
Julie K. Brown
PERSON
Carpenter
PERSONSweet
PERSON
Heath
PERSON
Bronx
LOCATIONStokes
PERSONWalsh
PERSONthe Southern District
LOCATIONSubpoena Duces
PERSONThompson
PERSONJimenez
PERSON
Southern District of New York
ORGANIZATION
Scarlett Johansson
PERSONthe Second Circuit's
ORGANIZATION
David Boies
PERSON