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dment due process rights, the government's method of acquiring the evidence must be so egregious that it 'shocks the conscience.'" United States v. Loera, 333 F. Supp. 3d 172, 184 (E.D.N.Y. 2018) (internal quotation marks and citations omitted). "The concept of fairness embodied in the Fifth Amendme
ishes "some extraordinary circumstance or compelling need." Martindell, 594 F.2d at 296. After concluding that reliance on the protective order was unreasonable,36 Chief Judge McMahon found that the "Government [ ] persuasively demonstrated extraordinary circumstances," citing "significant 36 See, e.g., hit'!
dment due process rights, the government's method of acquiring the evidence must be so egregious that it 'shocks the conscience.'" United States v. Loera, 333 F. Supp. 3d 172, 184 (E.D.N.Y. 2018) (internal quotation marks and citations omitted). "The concept of fairness embodied in the Fifth Amendme
ishes "some extraordinary circumstance or compelling need." Martindell, 594 F.2d at 296. After concluding that reliance on the protective order was unreasonable,36 Chief Judge McMahon found that the "Government [ ] persuasively demonstrated extraordinary circumstances," citing "significant 36 See, e.g., hit'!
dment due process rights, the government's method of acquiring the evidence must be so egregious that it 'shocks the conscience.'" United States v. Loera, 333 F. Supp. 3d 172, 184 (E.D.N.Y. 2018) (internal quotation marks and citations omitted). "The concept of fairness embodied in the Fifth Amendmen
ishes "some extraordinary circumstance or compelling need." Martindell, 594 F.2d at 296. After concluding that reliance on the protective order was unreasonable,36 Chief Judge McMahon found that the "Government [ ] persuasively demonstrated extraordinary circumstances," citing "significant '6 See, e.g., Intl E
Entities connected to both Loera and unreasonable,36

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