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West 1998 No Claim to Orig. U.S. Govt. Works Not Reported in F.Supp. (Cite as: 1998 WL 67676 (S.D.N.Y.)) UNITED STATES OF AMERICA, Plaintiff, v. Jeffrey E. EPSTEIN and Ivan S. Fisher, Defendants. No. 96 Civ. 8307(DC). United States District Court, S.D. New York. Feb. 19, 1998. Mary Jo White, United States At
tates Department of State took possession of the building pursuant to the Foreign Missions Act, 22 U.S.C. s 4301 et seq. OFM leased the building to Epstein in 1992. Epstein eventually sublet the premises to Fisher, purportedly without the Government's consent. Fisher, in turn, sublet a portion of the p
N.Y.)) UNITED STATES OF AMERICA, Plaintiff, v. Jeffrey E. EPSTEIN and Ivan S. Fisher, Defendants. No. 96
N.Y.)) UNITED STATES OF AMERICA, Plaintiff, v. Jeffrey E. EPSTEIN and Ivan S. Fisher, Defendants. No. 96 C
and inexpensive determination' of civil disputes by encouraging full disclosure of all evidence that might conceivably be relevant." Martindell v. International Tel. & Tel. Corp., 594 F.2d 291, 295 (2d Cir.1979). Unless protective orders are "fully and fairly enforceable," persons relying upon such orders will
West 1998 No Claim to Orig. U.S. Govt. Works Not Reported in F.Supp. (Cite as: 1998 WL 67676 (S.D.N.Y.)) UNITED STATES OF AMERICA, Plaintiff, v. Jeffrey E. EPSTEIN and Ivan S. Fisher, Defendants. No. 96 Civ. 8307(DC). United States District Court, S.D. New York. Feb. 19, 1998. Mary Jo White, United States At
States Department of State took possession of the building pursuant to the Foreign Missions Act, 22 U.S.C. s 4301 et seq. OFM leased the building to Epstein in 1992. Epstein eventually sublet the premises to Fisher, purportedly without the Government's consent. Fisher, in turn, sublet a portion of the p
N.Y.)) UNITED STATES OF AMERICA, Plaintiff, v. Jeffrey E. EPSTEIN and Ivan S. Fisher, Defendants. No. 96
N.Y.)) UNITED STATES OF AMERICA, Plaintiff, v. Jeffrey E. EPSTEIN and Ivan S. Fisher, Defendants. No. 96 C
and inexpensive determination' of civil disputes by encouraging full disclosure of all evidence that might conceivably be relevant." Martindell v. International Tel. & Tel. Corp., 594 F.2d 291, 295 (2d Cir.1979). Unless protective orders are "fully and fairly enforceable," persons relying upon such orders will b
West 1998 No Claim to Orig. U.S. Govt. Works Not Reported in F.Supp. (Cite as: 1998 WL 67676 (S.D.N.Y.)) UNITED STATES OF AMERICA, Plaintiff, I Jeffrey E. EPSTEIN and Ivan S. Fisher, Defendants. No. 96 Civ. 8307(DC). United States District Court, S.D. New York. Feb. 19, 1998. Mary Jo White, United States At
States Department of State took possession of the building pursuant to the Foreign Missions Act, 22 U.S.C. s 4301 et seq. OFM leased the building to Epstein in 1992. Epstein eventually sublet the premises to Fisher, purportedly without the Government's consent. Fisher, in turn, sublet a portion of the p
.N.Y.)) UNITED STATES OF AMERICA, Plaintiff, I Jeffrey E. EPSTEIN and Ivan S. Fisher, Defendants. No. 96
.N.Y.)) UNITED STATES OF AMERICA, Plaintiff, I Jeffrey E. EPSTEIN and Ivan S. Fisher, Defendants. No. 96 C
dy, and inexpensive determination' of civil disputes by encouraging full disclosure of all evidence that might conceivably be relevant." Martindell International Tel. & Tel. Corp., 594 F.2d 291, 295 (2d Cir.1979). Unless protective orders are "fully and fairly enforceable," persons relying upon such orders will b
lieving Boies Schiller & Flexner LLP (the "Law Finn") of its obligations under the protective order issued on November 29, 2018, in Jane Doe 43 v. Jeffrey Epstein. et al. I7-CV-616 (IGK) (SN) (S.D.N.Y.). The purpose of such order is to permit the Law Firm to comply with a grand jury subpoena and provide mate
Page: EFTA00029951 →r issued on November 29, 2018, in Jane Doe 43 v. Jeffrey Epstein. et al. I7-CV-616 (IGK) (SN) (S.D.N.Y.).
Page: EFTA00029951 →promote the settlement of disputes."). *3 In response to an identical application seeking to modify a protective order in a different case between Epstein and an alleged victim, another judge in this District has reached a different conclusion. That judge found that Epstein's reliance on the protecti
Page: EFTA00029952 →xceptional circumstances or a compelling need. In re Grand Jury Subpoena Duces Tecum, 945 F.2d 1221, 1224 (2d Cir. 1991); see also ? Martindell v. International Tel. and Tel. Corp. 594 F.2d 291 (2d Cir. 1979). Because the Government does not argue that the Protective Order was improvidently granted (nor could
Page: EFTA00029952 →n of copies of discovery and related materials related to the Litigation. The Subpoena was validly issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of Title 18, United States Code, Sections 1591 and 1594(c) (unlawfully trafficking minors) and Section 2422(b)
ce and scope of the Investigation in this district is not publicly known. While counsel for certain victims are aware of the Investigation, neither Epstein nor other subjects of the investigation are believed to be similarly aware. Accordingly, the ordinary exercise of grand July power to "subpoena witn
issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of T
d a balancing test to evaluate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access to discovery materials
r to unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "Application"), in connection with the matter Jane Doe 43 v. Epstein, et al. ("Jane Doe"), 17 Civ. 616 (JGK) (SN) (the "Litigation"), a copy of which is attached hereto as Exhibit A. Background As described in the A
n of copies of discovery and related materials related to the Litigation. The Subpoena was validly issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of Title 18, United States Code, Sections 1591 and 1594(c) (unlawfully trafficking minors) and Section 2422(b)
issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of T
d a balancing test to evaluate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access to discovery materials
elieving Boies Schiller & Flexner LLP (the "Law Firm") of its obligations under the protective order issued on November 29, 2018, in Jane Doe 43 v. Jeffrey Epstein, et al. 17-CV-616 (JGK)(SN) (S.D.N.Y.). The purpose of such order is to permit the Law Firm to comply with a grand jury subpoena and provide materi
to promote the settlement of disputes."). In response to an identical application seeking to modify a protective order in a different case between Epstein and an alleged victim, another judge in this District has reached a different conclusion. That judge found that Epstein's reliance on the protective
r issued on November 29, 2018, in Jane Doe 43 v. Jeffrey Epstein, et al. 17-CV-616 (JGK)(SN) (S.D.N.Y.).
hed exceptional circumstances or a compelling need. In re Grand Jury Subpoena Duces Tecum 945 F.2d 1221, 1224 (2d Cir. 1991)• see also Martindell v. International Tel. and Tel. Corp., 594 F.2d 291 (2d Cir. 1979). Because the Government does not argue that the Protective Order was improvidently granted (nor could
n of copies of discovery and related materials related to the Litigation. The Subpoena was validly issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of Title 18, United States Code, Sections 1591 and 1594(c) (unlawfully trafficking minors) and Section 2422(b)
ce and scope of the Investigation in this district is not publicly known. While counsel for certain victims are aware of the Investigation, neither Epstein nor other subjects of the investigation are believed to be similarly aware. Accordingly, the ordinary exercise of grand July power to "subpoena witn
issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of T
d a balancing test to evaluate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access to discovery materials
n of copies of discovery and related materials related to the Litigation. The Subpoena was validly issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of Title 18, United States Code, Sections 1591 and 1594(c) (unlawfully trafficking minors) and Section 2422(b)
ce and scope of the Investigation in this district is not publicly known. While counsel for certain victims are aware of the Investigation, neither Epstein nor other subjects of the investigation are believed to be similarly aware. Accordingly, the ordinary exercise of grand jury power to "subpoena witn
issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of T
d a balancing test to evaluate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access to discovery materials
Entities connected to both Jeffrey Epstein and International Tel

Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Woody Allen
PERSON
George W. Bush
PERSON
Stephen Hawking
PERSONSouthern District
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Virginia Giuffre
PERSON
Bill Richardson
PERSON
David Boies
PERSON
Southern District of New York
ORGANIZATION
United States District Court
ORGANIZATIONSecond Circuit
ORGANIZATIONFisher
PERSONSweet
PERSON
Boies Schiller
ORGANIZATIONRoach
PERSON
Orange
LOCATION