Epstein Secrets

the litigation."). But this is not a case where the "conditions contemplated by the Court for revisiting the Protective Order have now occurred." ? Allen v. City of N.Y. 420 F. Supp. 2d 295, 301 (S.D.N.Y. 2006). All parties to the Protective Order have not been given notice and an opportunity to be h

xceptional circumstances or a compelling need. In re Grand Jury Subpoena Duces Tecum, 945 F.2d 1221, 1224 (2d Cir. 1991); see also ? Martindell v. International Tel. and Tel. Corp. 594 F.2d 291 (2d Cir. 1979). Because the Government does not argue that the Protective Order was improvidently granted (nor could

tig., 821 F.2d 139, 147 (2d Cir. 1987)); see also Allen v. City of New York, 420 F.Supp.2d 295, 301 (S.D

d a balancing test to evaluate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access to discovery materials

tig., 821 F.2d 139, 147 (2d Cir. 1987)); see also Allen v. City of New York, 420 F.Supp.2d 295, 301 (S.D

d a balancing test to evaluate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access to discovery materials

isiting the Protective Order have now occurred." Allen v. City of N.Y. 420 F. Supp. 2d 295, 301 (S.D.N.Y

hed exceptional circumstances or a compelling need. In re Grand Jury Subpoena Duces Tecum 945 F.2d 1221, 1224 (2d Cir. 1991)• see also Martindell v. International Tel. and Tel. Corp., 594 F.2d 291 (2d Cir. 1979). Because the Government does not argue that the Protective Order was improvidently granted (nor could

tig., 821 F.2d 139, 147 (2d Cir. 1987)); see also Allen v. City of New York, 420 F.Supp.2d 295, 301 (S.D

d a balancing test to evaluate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access to discovery materials