Epstein Secrets

ntervention as of right."); United Stalest. AT & T Co., 642 F.2d 1285, 1292 (D.C.Cir.1980); Sackman I. Liggett Group, Inc., 167 F.R.D. 6, 20-21 (E.D.N.Y. 1996). In allowing intervention, this Court notes that Garfinkel and Katzman have not demonstrated that Rosenbaum in fact served as their lawyer

hought processes of Plaintiffs attorneys will be revealed. See also In re Joint Eastern & Southern District Asbestos Litigation, 119 F.R.D. 4, 5-6 (E.D.N.Y. & S.D.N.Y. 1988) (book of photographs, compiled by plaintiff's attorney, showing various forms of asbestos to which plaintiff had been exposed, was d

to Orig. US Gov. Works. https://web2.westlaw.contrint/printstream.aspers=WLW11.07&pbc=8C6E23F9,Sidecti n ObAPIAI EFTA00177915 Page 10 of 25 183 F.R.D. 458,51 Fed. R. Evid. Serv. 35 (Cite as: 183 F.R.D. 458) L . way that the attorney client priv- ilege can. Whether the information involved is fac

ranceX.com, Inc., No. 06-cv-2225, 2010 WL 11606632, at *4 14 CONFIDENTIAL SDNY_GM_00000888 EFTA 00114972 EFTA01263259 To Be Filed Under Seal (E.D.N.Y. Mar. 15, 2010) (order was not improvidently granted where "parties were concerned about exchanging commercially sensitive material with their direct

is more difficult to show a party reasonably relied on a blanket order in producing documents or submitting to a deposition." Id (quoting EPDM, 255 F.R.D. at 319). The second factor—the language of the Protective Order itself—similarly weighs in favor of modification. The Protective Order provided tha

vant because they "show why the victims did not receive proper notifications about the non-prosecution agreement that the [United States Attorney's Office for the Southern District of Florida] negotiated with Epstein." (DE 266 at 11). The Court concludes that the materials are not relevant in that regard. First, the Court find

ket 07/06/2015 Page 12 of 51 if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. Atlanta Gas Light Co., 248 F.R.D. 663,668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication I. Grolier, Inc., that "the literal language o

foundation for the Court to apply foreign law to Defendant's claims. See Tansey v. Cochlear Ltd., No. 13-CV-4628 SJF SIL, 2014 WL 4676588, at •4 (E.D.N.Y. Sept. 18, 2014) ("the party relying on foreign law has the burden of showing such law bars production of documents." (quoting BrightEdge Techs., In

l defense interest, which cloaks related communications in privilege, and a common problem, to which the privilege does not apply. Cgiazaryan, 290 F.R.D. at 434 (citing Finkeiman v. Klaus, 2007 WL 4303538, at *4 (N.Y.Sup.Ct. Nov. 28, 2007)). "IA] limited common purpose (that) necessitates disclosure"

FragranceNetcom, Inc. v. Fragrancel.com, Inc., No. 06-cv-2225, 2010 WL 11606632, at •4 14 SDNY_GM_00000888 EFTA00086699 To Be Filed Under Seal (E.D.N.Y. Mar. 15, 2010) (order was not improvidently granted where "parties were concerned about exchanging commercially sensitive material with their direct

is more difficult to show a party reasonably relied on a blanket order in producing documents or submitting to a deposition.' Id. (quoting EPDM, 255 F.R.D. at 319). The second factor—the language of the Protective Order itself-similarly weighs in favor of modification. The Protective Order provided tha

Detention 551 EFTA00191620 there are no such conditions by a "preponderance of the evidence." See United States I Tedder, 903 F. Supp. 344, 345 (N.D.N.Y. 1995)citing United States v. Martin 782 F.2d 1141, 1146 (2d Cir. 1986); 18 U.S.C. § 3I42(c). It is not necessary that the government prove both fli

vernment is required to demonstrate that there are grounds for a hearing under the specific provisions of either 3142(f)(1) or (f)(2)." Butler, 165 F.R.D. at 71. "When there exists one or more grounds for holding a hearing under those provisions, the government may proceed on the theory of risk of fli

vant because they "show why the victims did not receive proper notifications about the non-prosecution agreement that the [United States Attorney's Office for the Southern District of Florida] negotiated with Epstein." (DE 266 at 11). The Court concludes that the materials are not relevant in that regard. First, the Court find

07/06/2015 Page 12 of 51 if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. v. Atlanta Gas Light Co., 248 F.R.D. 663,668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Grolier, Inc., that "the literal language o

EFTA00182828 Page 18 of 20 908 F.Supp. 1265 908 F.Supp. 1265 (Cite as: 908 F.Supp. 1265) Memorandum of Decision and Order, October 19, 1995 (E.D.N.Y.). In Brechner, a defendant subjec- ted to a similar truthfulness obligation was asked in a debriefing session whether or not he had received unrepo

ere, preventing Epstein from identifying Plaintiffs' in subpoenas and other type discovery overwhelmingly inhibits discovery. Ees Doe v. Evans, 202 F.R.D. at 176 (E.D. P.A. 2001) (denying protective order where alleged sexual assault victim did not demonstrate a serious specific injury and allowing De