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ce in its entirety is probative of the issues which will be raised in the Motion to Dismiss, including whether the statute of limitations has run on Jane Doe's claim, whether the Court in the Jane Doe Matter has personal jurisdiction over the defendants, and whether the Motion to Dismiss should be granted
rder 1. The Court Has Broad Discretion to Modify the Protective Order This Court has broad power to modify existing protective orders. S.E.C. v. TheStreetcom, 273 F.3d 222, 231 (2d Cir. 2001). Before modifying a protective order, the Court must first determine if the parties to the original order "reasona
re at issue here. See DE 6351, p. 23. Accordingly, the request to intervene should be denied. To the extent this Court will consider L.M., E.W., and Jane Doe's Joinder in Motion for Order to Show Cause and Motion for Discovery, to Access Sanctions and Costs for Other Appropriate Relief (DE 6345), this resp
nvincing is a higher standard and requires a high probability of success"). Importantly, the burden to prove contempt is on the Movants. Carroll v. TheStreetcom, Inc., II-CV-81173, 2014 WL 5474048, at *9 (S.D. Fla. Apr. 10, 2014). Fowler White is "not tasked with the affirmative responsibility of reversely
case. AUSA- I also does not believe she ever received any such discovery materials. (Ex. 4 at 6). 66 EFTA00103091 requested the same relating to Jane Doe 43 v. Epstein, et al., 17 Civ. 0616 (JGK) (SN). Because of the ongoing and covert nature of the grand jury investigation, and consistent with its st
ntobello v. United States, No. 94 Cr. (RPP), 1998 WL 113950 (S.D.N.Y. Mar. 13, 1998) 21 Sch. Dist. No. 7, 167 F.3d 784 (2d Cir. 1999) 61 SEC v. TheStreetcom, 273 F.3d 222 (2d Cir. 2001) 109, 113 viii EFTA00103007 Silver, 15 Cr. 93 (VEC) 275 Skelos, 15 Cr. 317 (KMW) 275 Smith v. Maryland, 442
Entities connected to both Jane Doe and TheStreetcom

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Scarlett Johansson
PERSON
United States
LOCATIONthe Southern District
LOCATIONMaria Farmer
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSONMartin Weinberg
PERSONthe Eleventh Circuit
ORGANIZATION
Julie K. Brown
PERSON
Southern District of New York
ORGANIZATION
David Boies
PERSON
Bill Richardson
PERSON
Lesley Groff
PERSON
Supreme Court
ORGANIZATION
George Mitchell
PERSON
Colorado
LOCATION
Michael Jackson
PERSON
Adriana Ross
PERSON