Epstein Secrets

t seal the entire court record, as happened 4 EFTA00600018 Case 9:08-cv-80736-KAM Document 295 Entered on FLSD Docket 01/26/2015 Page 5 of 18 in Brown and Wilson. Instead, because we are seeking only that the Court temporarily seal discrete documents rather than complete pleadings or an entire doc

even if the communications themselves are not privileged. See Charles E. Hill & Associates, Inc. v. ABT Electronics, Inc., 854 F. Supp. 2d 427, 430 (E.D. Tex. 2012) (designating discovery material including settlement communications as "Outside Counsel Eyes Only Confidential Information" and cautioning pa

t seal the entire court record, as happened 4 EFTA00210720 Case 9:08-cv-80736-KAM Document 295 Entered on FLSD Docket 01/26/2015 Page 5 of 18 in Brown and Wilson. Instead, because we are seeking only that the Court temporarily seal discrete documents rather than complete pleadings or an entire doc

even if the communications themselves are not privileged. See Charles E. Hill & Associates, Inc. g ABT Electronics, Inc., 854 F. Supp. 2d 427, 430 (E.D. Tex. 2012) (designating discovery material including settlement communications as "Outside Counsel Eyes Only Confidential Information" and cautioning pa

EFTA00582791 circumstances or particularized needs@ standard because we are not asking that the Court seal the entire court record, as happened in Brown and Wilson. Instead, because we are seeking only that the Court temporarily seal discrete documents rather than complete pleadings or an entire doc

to chill settlement efforts) (citations omitted). 14 EFTA00582800 Charles E Associates, Inc. v. ART Electronics, Inc, 854 F. Supp. 2d 427, 430 (E.D. Tex. 2012) (designating discovery material including settlement communications as AOutside Counsel Eyes Only Confidential Information@ and cautioning pa