Epstein Secrets

ing factual information: I. Grand jury subpoenas were issued to an entity ("Recipient") after the Government opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipient concluded that it could not turn over materials responsive to the grand jury subpoena absent a

t opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipi

overnment opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. Th

he standard for "good cause" in the civil context when evaluating whether to modify a protective order entered in a criminal case); United States v. Wecht, 484 F.3d 194, 211 (3rd Cir. 2007) (same). 2 EFTA00097199 Caseas2Cealig3GDACOMEDitiant91202QIER909R)272eafitteiSof 5 case in other civil proceed

ing factual information: I. Grand jury subpoenas were issued to an entity ("Recipient") after the Government opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipient concluded that it could not turn over materials responsive to the grand jury subpoena absent a

t opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipi

overnment opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. Th

he standard for "good cause" in the civil context when evaluating whether to modify a protective order entered in a criminal case); United States v. Wecht, 484 F.3d 194, 211 (3rd Cir. 2007) (same). 2 EFTA00101996 Case 1:20-cr-00330-AJN Document 51 Filed 09/02/20 Page 3 of 5 case in other civil proc

Haddon, Morgan and Foreman. P.c Jeffrey Paglluca II A D D O N M OR G A N FOREMAN 303.

domain, and which are entitled to privacy and confidentiality" are discretionary and "form an integral part of trial management"); United States v. Wecht, 484 F.3d 194, 211 (3d Cir. 2007), as amended (July 2, 2007) ("it would have been proper for the District Court to unseal the records pursuant to i

he standard for "good cause" in the civil context when evaluating whether to modify a protective order entered in a criminal case); United States v. Wecht, 484 F.3d 194, 211 (3rd Cir. 2007) (same). 2 EFTA00026706 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 51 Filed 09/02/20 Page 3 of 5 case

ing factual information: I. Grand jury subpoenas were issued to an entity ("Recipient") after the Government opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipient concluded that it could not turn over materials responsive to the grand jury subpoena absent a

t opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipi

overnment opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. Th

he standard for "good cause" in the civil context when evaluating whether to modify a protective order entered in a criminal case); United States v. Wecht, 484 F.3d 194, 211 (3rd Cir. 2007) (same). 2 EFTA00028056 --- PAGE BREAK --- CaseaseaeratIMIDACWEEDitiebile109120aQIERSOM92eaptefraof 5 case in

ing factual information: I. Grand jury subpoenas were issued to an entity ("Recipient") after the Government opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipient concluded that it could not turn over materials responsive to the grand jury subpoena absent a

t opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. The Recipi

overnment opened a grand jury investigation into Jeffrey Epstein and his possible co- conspirators; 2. Th