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had at least called the witness before the grand jury). The subject matter of the Litigation also demonstrates the extraordinary circumstances of the Government's Investigation and Application, insofar as the materials at issue here appear not to be of the sort that ordinarily would provide protection against Government investigation. See
k rendering that opinion in even further conflict with the well-reasoned decisions of numerous other Circuits. In particular, the Fourth, Ninth, and Eleventh Circuits have each adopted a per se rule favoring enforcement of a grand jury subpoena even where a protective order exists. See In re Grand Jury Subpoena,
had at least called the witness before the grand jury). The subject matter of the Litigation also demonstrates the extraordinary circumstances of the Government's Investigation and Application, insofar as the materials at issue here appear not to be of the sort that ordinarily would provide protection against Government investigation. See
k rendering that opinion in even further conflict with the well-reasoned decisions of numerous other Circuits. In particular, the Fourth, Ninth, and Eleventh Circuits have each adopted a per se rule favoring enforcement of a grand jury subpoena even where a protective order exists. See In re Grand Jury Subpoena,
had at least called the witness before the grand jury). The subject matter of the Litigation also demonstrates the extraordinary circumstances of the Government's Investigation and Application, insofar as the materials at issue here appear not to be of the sort that ordinarily would provide protection against Government investigation. See
k rendering that opinion in even further conflict with the well-reasoned decisions of numerous other Circuits. In particular, the Fourth, Ninth, and Eleventh Circuits have each adopted a per se rule favoring enforcement of a grand jury subpoena even where a protective order exists. See In re Grand Jury Subpoena,
had at least called the witness before the grand jury). The subject matter of the Litigation also demonstrates the extraordinary circumstances of the Government's Investigation and Application, insofar as the materials at issue here appear not to be of the sort that ordinarily would provide protection against Government investigation. See
k rendering that opinion in even further conflict with the well-reasoned decisions of numerous other Circuits. In particular, the Fourth, Ninth, and Eleventh Circuits have each adopted a per se rule favoring enforcement of a grand jury subpoena even where a protective order exists. See In re Grand Jury Subpoena,
Entities connected to both the Government's Investigation and Application and Eleventh Circuits

Jeffrey Epstein
PERSONRoach
PERSONChemical Bank
ORGANIZATIONMeserve, Mumper & Hughes
ORGANIZATIONMartindell
PERSONthe Protective Order
ORGANIZATIONInternational Tel
ORGANIZATIONSouthern District
LOCATIONthe Federal Criminal Code
ORGANIZATIONFourt
ORGANIZATIONTeL Corp.
ORGANIZATIONJ. Gorenstein
PERSONBranzburg v. Hayes
PERSON
Prince Andrew
PERSON
David Boies
PERSON
Orange
LOCATION
Boies Schiller
ORGANIZATION
Department of Justice
ORGANIZATIONthe "Litigation"
ORGANIZATIONSubpoena Duces
PERSON