Epstein Secrets

full compliance.33 (Exs. 8 & 9). Accordingly, the Government applied a pate and under seal to each relevant court (Judge Sweet and Magistrate Judge Sarah Netbum, respectively) to request that each court modify the respective protective orders to permit compliance with the subpoenas. (Def. Mot. 3, Ex. C). Fo

o old, at most the door is barely ajar."). Substantial prejudice is just that—substantial, actual, non-speculative prejudice. See United States v. Birney, 686 F.2d 102, 105-06 (2d Cir. 1982) (a defendant's "proof of prejudice must be definite and not speculative"); see also United States v. Henderson,

full compliance.33 (Exs. 8 & 9). Accordingly, the Government applied a pate and under seal to each relevant court (Judge Sweet and Magistrate Judge Sarah Netbum, respectively) to request that each court modify the respective protective orders to permit compliance with the subpoenas. (Def. Mot. 3, Ex. C). Fo

o old, at most the door is barely ajar."). Substantial prejudice is just that—substantial, actual, non-speculative prejudice. See United States v. Birney, 686 F.2d 102, 105-06 (2d Cir. 1982) (a defendant's "proof of prejudice must be definite and not speculative"); see also United States v. Henderson,

ll compliance.33 (Exs. 8 & 9). Accordingly, the Government applied ex parte and under seal to each relevant court (Judge Sweet and Magistrate Judge Sarah Netbum, respectively) to request that each court modify the respective protective orders to permit compliance with the subpoenas. (Def. Mot. 3, Ex. C). Fo

ited States v. Biaggi, 909 F.2d 662 (2d Cir. 1990) 298, 300 United States v. Bin Laden, 91 F. Supp. 2d 600 (S.D.N.Y. 2000) 240 United States v. Birney, 686 F.2d 102 (2d Cir. 1982) 61, 65 United States v. Bbrell, 470 F.2d 113 (2d Cir. 1972) 183 EFTA00103009 United States v. Blakney, 941 F.2