Epstein Secrets

[email protected] ATTORNEY TO BE NOTICED Michael Ross Tein Lewis Tein 3059 Grand Avenue Suite 340 E

by the corporations which are defendants in the civil case, the considerations . . . militating against disclosure are beside the point.") (citing Douglas Oil Co. of Calif. v. Petrol Stops Nw., 441 U.S. 211 (1979)). In response to such third-party subpoenas to law-enforcement witnesses, we anticipate that it

GLE County Buyer Information JOHNSON. ELIZABETH ROSS EPSTEIN. JEFFREY E 457 MADISON AVE NEW YORK, NY

F.3d at 1347. "The district court has 'substantial discretion' in determining whether grand jury materials should be released." Id. at 1349 (quoting Douglas Oil Co. v. Petrol Stops N.W., 441 U.S. 211, 223, 99 S. Ct. 1667, 60 L. Ed. 2d 156 (1979)). For internal use only SDNY_GM_00059572 CONFIDENTIAL - PURSUANT

515-3148 Email: ATTORNEY TO BE NOTICED Michael Ross Tein Lewis Tein 3059 Grand Avenue Suite 340 C

by the corporations which are defendants in the civil case, the considerations . . . militating against disclosure are beside the point.") (citing Douglas Oil Co. of Calif Petrol Stops Nw., 441 U.S. 211 (1979)). In response to such third-party subpoenas to law-enforcement witnesses, we anticipate that it will