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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
ent Orange" Prod. Liab. Litig., 821 F.2d 139, 147 (2d Cir. 1987)); see also Alien v. City of New York, 420 F.Supp.2d 295, 301 (S.D.N.Y. 2006) (Mag. J. Gorenstein) (analyzing the differently-situated interests of civil litigants but where, as here, the relevant protective order specified that a party could ob
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
ent Orange" Prod. Liab. Litig., 821 F.2d 139, 147 (2d Cir. 1987)); see also Allen v. City of New York, 420 F.Supp.2d 295, 301 (S.D.N.Y. 2006) (Mag. J. Gorenstein) (analyzing the differently-situated interests of civil litigants but where, as here, the relevant protective order specified that a party could ob
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
ent Orange" Prod. Liab. Litig., 821 F.2d 139, 147 (2d Cir. 1987)); see also Allen v. City of New York, 420 F.Supp.2d 295, 301 (S.D.N.Y. 2006) (Mag. J. Gorenstein) (analyzing the differently-situated interests of civil litigants but where, as here, the relevant protective order specified that a party could ob
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
ent Orange" Prod. Liab. Litig., 821 F.2d 139, 147 (2d Cir. 1987)); see also Allen v. City of New York, 420 F.Supp.2d 295, 301 (S.D.N.Y. 2006) (Mag. J. Gorenstein) (analyzing the differently-situated interests of civil litigants but where, as here, the relevant protective order specified that a party could ob
Entities connected to both the Government's Investigation and Application and J. Gorenstein

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