Epstein Secrets

way, men are but guilded loam, or painted clay." W. Shakespeare, RICHARD II, Acr 1, SCENE 1, lines 17

10 of access is not absolute and sealing is appropriate in connection with grand jury proceedings. As explained by Judge Jordan in United States v. Steinger, 626 F. Supp. 2d 1231 (S.D. Fl. 2009): "The proper functioning of our grand jury system depends upon the secrecy of grand jury proceedings," Dougla

away, men are but guilded loam, or painted clay." W. Shakespeare, RICHARD II, Am. 1, SCENE 1, lines 1

Court , 464 U.S. 501 (1984)] so as to warrant sealing, and provides good cause under the common-law access balancing test to preclude disclosure. Steinger , 626 F. Supp. 2d at 1235-36 (brackets in original omitted). See also In re Petition of American Historical Ass 'n , 62 F. Supp. 2d 1100, 1103 (S.D

away, men are but guilded loam, or painted clay." W. Shakespeare, RICHARD II, Am. 1, SCENE 1, lines 1

ght of access is not absolute and sealing is appropriate in connection with grand jury proceedings. As explained by Judge Jordan in United States v. Steinger , 626 F. Supp. 2d 1231 (S.D. Fl. 2009): "The proper functioning of our grand jury system depends upon the secrecy of grand jury proceedings," Doug

away, men are but guilded loam, or painted clay." W. Shakespeare, RICHARD II, Am. 1, SCENE 1, lines 1

Court , 464 U.S. 501 (1984)] so as to warrant sealing, and provides good cause under the common-law access balancing test to preclude disclosure. Steinger , 626 F. Supp. 2d at 1235-36 (brackets in original omitted). See also In re Petition of American Historical Ass 'n , 62 F. Supp. 2d 1100, 1103 (S.D

ETITION FOR WRIT OF CERTIORARI AND RESPONSE TO E.W.'S MOTION TO DISIMISS PETITION FOR LACK OF JURISD

ly entitled to protection, as there may have been accusations made for which no indictment was returned." Id. at 218 n.8; see also United States v. Steinger, No. 08-21158-CR, 2009 WL 1674798, at *3 (S.D. Fla. Apr. 28, 2009) (discussing the "devastating consequences" from revealing names of "those person

way, men are but guilded loam, or painted clay." W. Shakespeare, RICHARD II, ACT 1, SCENE 1, lines 17

r Court, 464 U.S. 501 (1984)] so as to warrant scaling, and provides good cause under the common-law access balancing test to preclude disclosure. Steinger, 626 F. Supp. 2d at 1235-36 (brackets in original omitted). See also In re Petition of American Historical Assn, 62 F. Supp. 2d 1100, 1103 (S.D.N.Y.

larly at page 5, the declaration states: "After C.W. had been notified of the terms of the agreement

10 of access is not absolute and sealing is appropriate in connection with grand jury proceedings. As explained by Judge Jordan in United States v. Steinger, 626 F. Supp. 24i 1231 (S.D. Fl. 2009): "The proper functioning of our grand jury system depends upon the secrecy of grand jury proceedings," Dougl

agreement was signed, four victims [including C.W.] were contacted and these provisions were discuss

cy seeks to protect . . unindicted individuals from the anxiety, embarrassment, and public castigation that may result from disclosure.") (cited in Steinger). 5 08-80736-CV-MARRA 000941 EFTA00230765 e•;;S",:%%::: - - • /len" Case 9:08-cv-80736-KAM Document 60 Entered on FLSD Docket 04/07/2011 Pag