Epstein Secrets

t could have filed a writ of mandamus, since "mandamus lies to compel a judge to unseal documents shown to be material and necessary in litigation," United States v. Davis, 702 F.2d 418, 423 (2d Cir. 1983). But the Government has done neither of the above; instead, it has moved pursuant to the All Writs Act. I

odification on these grounds, I address this factor in light of the current proceedings before the Second Circuit. The term is not well understood. See United States v. Talco Contractors, Inc., 153 F.R.D. 501, 511 (W.D.N.Y. 1994) (observing that the Circuit "provided no guidance as to what might constitute `impr

cation of the Protective Order. Permissive intervention is the appropriate procedural device when any non-party seeks to modify a protective order. AT&T Corp. v. Sprint Corp., 407 F.3d 560, 562 (2d Cir. 2005) ("We have stated that permissive intervention is the proper method for a nonparty to seek a modifi

t could have filed a writ of mandamus, since "mandamus lies to compel a judge to unseal documents shown to be material and necessary in litigation," United States v. Davis, 702 F.2d 418, 423 (2d Cir. 1983). But the Government has done neither of the above; instead, it has moved pursuant to the All Writs Act. I

odification on these grounds, I address this factor in light of the current proceedings before the Second Circuit. The term is not well understood. See United States v. Talco Contractors, Inc., 153 F.R.D. 501, 511 (W.D.N.Y. 1994) (observing that the Circuit "provided no guidance as to what might constitute `impr

cation of the Protective Order. Permissive intervention is the appropriate procedural device when any non-party seeks to modify a protective order. AT&T Corp. v. Sprint Corp., 407 F.3d 560, 562 (2d Cir. 2005) ("We have stated that permissive intervention is the proper method for a nonparty to seek a modifi

006537 Arbitrator: Hon. Anthony J. Carpinello (Ret.) CLAIMANTS' PRE-HEARING BRIEF PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP 1285 Avenue of the Americas New York, New York 10019-6064 (212) 373-3000 Attorneys for Claimants Fortress VRF I LLC and Fortress Value Recovery Fund 1 LLC EFTA00613940 TA

ers v. LJM2 Capital Mgmt., LP, 794 A.2d 1276 (Del. Ch. 2002) 48 Am. Gen. Corp. v. Continental Airlines Corp., 622 A.2d 1 (Del. Ch. 1992) 48, 49 AT&T Corp. v. Lillis, 953 A.2d 241 (Del. 2008) 30 BASF Corp. v. POSM H Props. P'ship, LP, 09 Civ. 3608, 2009 WL 522721 (Del. Ch. March 3, 2009) 36 Chrysle