Epstein Secrets

ims' motion for a finding of violation of the CVRA is untimely, as that is when the victims must begin drafting reply pleadings. See United States! Jefferson County, 720 F.2d 1511, 1516 (nth Cir. 1983) (listing factors to be considered in determining whether motion to intervene is timely). CERTIFICATE OF CONFERE

r Court, 464 U.S. 501 (1984)] so as to warrant scaling, and provides good cause under the common-law access balancing test to preclude disclosure. Steinger, 626 F. Supp. 2d at 1235-36 (brackets in original omitted). See also In re Petition of American Historical Assn, 62 F. Supp. 2d 1100, 1103 (S.D.N.Y.

ims' motion for a finding of violation of the CVRA is untimely, as that is when the victims must begin drafting reply pleadings. See United States' Jefferson County, 720 F.2d 1511, 1516 (1Ith Cir. 1983) (listing factors to be considered in determining whether motion to intervene is timely). CERTIFICATE OF CONFER

10 of access is not absolute and sealing is appropriate in connection with grand jury proceedings. As explained by Judge Jordan in United States v. Steinger, 626 F. Supp. 24i 1231 (S.D. Fl. 2009): "The proper functioning of our grand jury system depends upon the secrecy of grand jury proceedings," Dougl

ims' motion for a finding of violation of the CVRA is untimely, as that is when the victims must begin drafting reply pleadings. See United States' Jefferson County, 720 F.2d 1511, 1516 (11th Cir. 1983) (listing factors to be considered in determining whether motion to intervene is timely). CERTIFICATE OF CONFER

cy seeks to protect . . unindicted individuals from the anxiety, embarrassment, and public castigation that may result from disclosure.") (cited in Steinger). 5 08-80736-CV-MARRA 000941 EFTA00230765 e•;;S",:%%::: - - • /len" Case 9:08-cv-80736-KAM Document 60 Entered on FLSD Docket 04/07/2011 Pag