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

ndertook before granting the order; and (4) the nature of reliance on the order." In re Ethylene Propylene Diene Monomer (EPDM) Antitrust Ling., 255 F.R.D. 308, 318 (D. Conn. 2009). The first factor—the scope of the Protective Order—favors granting the Government's application for modification. As discusse

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

ndertook before granting the order; and (4) the nature of reliance on the order." In re Ethylene Propylene Diene Monomer (EPDM) Antitrust Ling., 255 F.R.D. 308, 318 (1:10. Conn. 2009). The first factor—the scope of the Protective Order—favors granting the Government's application for modification. As discu

NDUM OF LAW IN SUPPORT OF INTERVENORS' MOTIONS FOR LEAVE TO INTERVENE AND TO MODIFY THE PROTECTIVE ORDER STEPTOE & JOHNSON LLP 1114 Avenue of the Americas New York, New York 10036 (212) 506-3900 October 5, 2017 CONFIDENTIAL - FILED UNDER SEAL EFTA00805389 TABLE OF CONTENTS PRELIMINARY STATEMENT

Minn. 2014) 4 Charter Oak Fire Ins. Co. v. Electrolux Home Prods., Inc., 287 F.R.D. 130 (E.D.N.Y. 2012) 11, 12 In re EPDM Antitrust Litt., 255 F.R.D. 308 (D. Conn. 2009) 12 Gambale v. Deutsche Bank AG, 377 F.3d 133 (2d Cir. 2004) v. Maxwell, No. 15 Civ. 7433, 2017 WL 1787934 (S.D.N.Y. May 3, 2017)