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e whether the defendant's statements would have tipped the scales in the defamation suit or would likely have led to the discovery of evidence. See Kungys v. United States, 485 U.S. 759, 771 (1988) ("It has never been the test of materiality that the misrepresentation or concealment would more likely t
government establishes "some extraordinary circumstance or compelling need." Martindell, 594 F.2d at 296. 36 See, e.g., Int'l Equity Invs., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314, at *8 (S.D.N.Y. Mar. 2, 2010) (finding that the parties' reliance on a civil protective order "was n
e whether the defendant's statements would have tipped the scales in the defamation suit or would likely have led to the discovery of evidence. See Kungys v. United States, 485 U.S. 759, 771 (1988) ("It has never been the test of materiality that the misrepresentation or concealment would more likely t
ound that the "Government [ ] persuasively demonstrated extraordinary circumstances," citing "significant 36 See, e.g., hit'! Equity Ines., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314, at *8 (S.D.N.Y. Mar. 2, 2010) (finding that the parties' reliance on a civil protective order "was n
e whether the defendant's statements would have tipped the scales in the defamation suit or would likely have led to the discovery of evidence. See Kungys v. United States, 485 U.S. 759, 771 (1988) ("It has never been the test of materiality that the misrepresentation or concealment would more likely t
ound that the "Government [ ] persuasively demonstrated extraordinary circumstances," citing "significant 36 See, e.g., hit'! Equity Ines., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314, at *8 (S.D.N.Y. Mar. 2, 2010) (finding that the parties' reliance on a civil protective order "was n
e whether the defendant's statements would have tipped the scales in the defamation suit or would likely have led to the discovery of evidence. See Kungys v. United States, 485 U.S. 759, 771 (1988) ("It has never been the test of materiality that the misrepresentation or concealment would more likely t
elling need." Martindell, 594 F.3d at 296. [hat t l "Got ,[ 1 Sive publ hat in a a grad i jury esti 37 See, e.g., Lit'! Equity Invs., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314, at *8 (S.D.N.Y. Mar. 2, 2010) (finding that the parties' reliance on a civil protective order "was n
e whether the defendant's statements would have tipped the scales in the defamation suit or would likely have led to the discovery of evidence. See Kungys v. United States, 485 U.S. 759, 771 (1988) ("It has never been the test of materiality that the misrepresentation or concealment would more likely t
found that the "Government [ ] persuasively demonstrated extraordinary circumstances," citing "significant '6 See, e.g., Intl Equity Invs., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314, at *8 (S.D.N.Y. Mar. 2, 2010) (finding that the parties' reliance on a civil protective order "was n
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