Epstein Secrets

651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "A in connection with the matter v. Ghislaine Maxwell, et al. ("M"), 15 Civ. 7433 (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the G

nformation simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). CONFIDENTIAL SDNY_GM_00000849 EFTA00066435 Page

simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). CONFIDENTIAL SDNY_GM_00000849 EFTA00066435 Page 4 Martin

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,

1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP the "A in connection with the matter v. Ghislaine Maxwell, et al. (a), (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the Government has s

nformation simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). EFTA00084803 Page 4 Martindell, the district cour

simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). EFTA00084803 Page 4 Martindell, the district court opined

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,

51, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "A in connection with the matter v. Ghislaine Maxwell, et at (a"), 15 Civ. 7433 (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the Gov

nformation simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). CONFIDENTIAL SDNY_GM_00000849 EFTA_00114933 EFTA0

simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). CONFIDENTIAL SDNY_GM_00000849 EFTA_00114933 EFTA01263242

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,