Epstein Secrets

court" and it "depend[s] on the judiciary in its role as an investigative body." United States v. Seals, 130 F.3d 451, 457 (D.C. Cir. 1997) (quoting Brown v. United States, 359 U.S. 41, 49 (1959)). As relevant here, the United States District Court for the District of Columbia has held that an order u

its Act must be justified by "'compelling necessity . . . shown with particularity." Howell Opinion, 2017 WL 3278929 at *3 (quoting In re Grand Jury Subpoena Duces Tecum, 797 F.2d 676, 681 (8th Cir. 1986)). 8. This application sets forth facts showing that there is a compelling necessity for a non- disclosure order

ii EFTA00100289 Other Authorities Stephen Rex Brown, Manhattan federal prosecutors declined to pursue

material is in the possession of a third- party, a defendant has standing to challenge a grand jury subpoena of that material. Matter of Grand Jury Subpoena Duces Tecum Dated Feb. 18, 1988, 685 F. Supp. 49, 51 (S.D.N.Y. 1988) (law firm could intervene and join motion to quash grand jury subpoena issued to private 1

any materials in the record. Accordingly, these assertions of privilege are inadequate. See Bogle v. McClure, 332 F.3d 347, 1358 (11th Cir. 2003); Brown v. City of Margate, 842 F.Supp. 515, 520 Should the Court allow the Government to assert privilege with regard to any of the materials, the victims

tionships" and that "[t]his principle has been applied to fiduciary relationships beyond the traditional trust context"); see also In re Grand Jury Subpoena Duces Tecum, 112 F.3d 910, 919-21 (8th Cir. 1997) (government attorneys have duty to report wrongdoing). Communications Facilitating Crime-Fraud-Misconduct Not

Nevertheless, after Capehart had read the official reports on the shooting, he confessed they had "forced me to deal with two uncomfortable truths: Brown never surrendered with his hands up, and Wilson was justified in shooting Brown." * Hate-crime hoax epidemic: Vilifying conservatives with various

documents that "might allow them to protect those very rights." (Id. at 15). By way of illustration, Petitioners offer the case of In re Grand Jury Subpoena Duces Tecum, where the Eighth Circuit broadly stated that "the general duty of public service calls upon government employees and agencies to favor disclosure

ii EFTA00097333 Other Authorities Stephen Rex Brown, Manhattan federal prosecutors declined to pursue

material is in the possession of a third- party, a defendant has standing to challenge a grand jury subpoena of that material. Matter of Grand Jury Subpoena Duces Tecum Dated Feb. 18, 1988, 685 F. Supp. 49, 51 (S.D.N.Y. 1988) (law firm could intervene and join motion to quash grand jury subpoena issued to private 1

ii EFTA00097651 Other Authorities Stephen Rex Brown, Manhattan federal prosecutors declined to pursue

material is in the possession of a third- party, a defendant has standing to challenge a grand jury subpoena of that material. Matter of Grand Jury Subpoena Duces Tecum Dated Feb. 18, 1988, 685 F. Supp. 49, 51 (S.D.N.Y. 1988) (law firm could intervene and join motion to quash grand jury subpoena issued to private 1

mental informant. Id. The burden to even obtain a Franks hearing is a heavy one, and such hearings are thus exceedingly rare. See United States v. Brown, 744 F. Supp. 558, 567 (S.D.N.Y. 1990) ("A defendant seeking to have the Court hold a Franks hearing bears a substantial burden."); United States v

the proper remedy.38 Indeed, none of the Second Circuit cases applying Martindell contemplate suppression as a remedy. See, e.g., In re Grand Jut), Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d at 1224 (remanding for findings "on whether the protective order was improvidently granted or whether the government

by any materials in the record. Accordingly, these assertions of privilege are inadequate. See Bogle. McClure, 332 F.3d 347, 1358 (11th Cir. 2003); Brown' City of Margate, 842 F.Supp. 515, 520 Should the Court allow the Government to assert privilege with regard to any of the materials, the victims w

tionships" and that "[t]his principle has been applied to fiduciary relationships beyond the traditional trust context"); see also In re Grand Jury Subpoena Duces Tecum, 112 F.3d 910, 919-21 (8th Cir. 1997) (government attorneys have duty to report wrongdoing). Communications Facilitating Crime-Fraud-Misconduct Not