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three times a day." Julie K. Brown, How ajiiture Trump Cabinet member gave a serial sex abuser the deal
is more difficult to show a party reasonably relied on a blanket order in producing documents or submitting to a deposition." Id (quoting EPDM, 255 F.R.D. at 319). The second factor—the language of the Protective Order itself—similarly weighs in favor of modification. The Protective Order provided tha
. 2006)). Merely filing a document with a court "'is insufficient to render that paper a judicial document subject to the right of public access."' Trump, 940 F.3d at 150 (quoting United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995) ("Amodeo I")). To be designated a judicial document, "the item f
ore difficult to show a party reasonably relied on a blanket order in producing documents or submitting to a deposition.') (quoting In re EPDM, 255 F.R.D. at 319). Since the Protective Order does not address specific deposition testimony or exhibit documents, the parties do not have demonstrated relian
. 2006)). Merely filing a document with a court "'is insufficient to render that paper a judicial document subject to the right of public access."' Trump, 940 F.3d at 150 (quoting United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995) ("Amodeo I")). To be designated a judicial document, "the item f
ore difficult to show a party reasonably relied on a blanket order in producing documents or submitting to a deposition.') (quoting In re EPDM, 255 F.R.D. at 319). Since the Protective Order does not address specific deposition testimony or exhibit documents, the parties do not have demonstrated relian
three times a day." Julie K. Brown, How a future Trump Cabinet member gave a serial sex abuser the deal
is more difficult to show a party reasonably relied on a blanket order in producing documents or submitting to a deposition.' Id. (quoting EPDM, 255 F.R.D. at 319). The second factor—the language of the Protective Order itself-similarly weighs in favor of modification. The Protective Order provided tha
nberg at Haley Capital, which was located in the Trump Tower. In late December 1993, Hoffenberg took Dr
ere, preventing Epstein from identifying Plaintiffs' in subpoenas and other type discovery overwhelmingly inhibits discovery. Ees Doe v. Evans, 202 F.R.D. at 176 (E.D. P.A. 2001) (denying protective order where alleged sexual assault victim did not demonstrate a serious specific injury and allowing De
Entities connected to both Donald Trump and F.R.D.

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Marc Rich
PERSON
Alan Dershowitz
PERSON
Virginia Giuffre
PERSON
Julie K. Brown
PERSON
United States
LOCATION
Bradley Edwards
PERSON
Prince Charles
PERSONMartin Weinberg
PERSON
New York
LOCATION
Barry Diller
PERSON
Alexander Acosta
PERSON
Colorado
LOCATIONMaria Farmer
PERSON
George Mitchell
PERSON
Woody Allen
PERSON