Epstein Secrets

d a balancing test to evaluate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access to discovery materials

a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "Application"), in connection with the matter Jane Doe 43 v. Epstein, et al. ("Jane Doe"), 17 Civ. 616 (JGK) (SN) (the "Litigation"), a copy of which is attached hereto as Exhibit A. Background As desc

hed 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 improvidently granted (nor could

for an order relieving Boies Schiller & Flexner LLP (the "Law Firm") of its obligations under the protective order issued on November 29, 2018, in Jane Doe 43 v. Jeffrey Epstein, et al. 17-CV-616 (JGK)(SN) (S.D.N.Y.). The purpose of such order is to permit the Law Firm to comply with a grand jury subpoe

for an order relieving Boies Schiller & Flexner LLP (the "Law Finn") of its obligations under the protective order issued on November 29, 2018, in Jane Doe 43 v. Jeffrey Epstein. et al. I7-CV-616 (IGK) (SN) (S.D.N.Y.). The purpose of such order is to permit the Law Firm to comply with a grand jury subp

xceptional 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 improvidently granted (nor could