Epstein Secrets

. glione number and e-mail] KCampbell-Law, PLLC BOIES SCHILLER FLEXNER UP v. Maxwell OPPOSING ATTORNE

sarily jeopardize the privacy and reputational interests of the named individuals. United States v. Smith, 776 F.2d 1104, 1114 (3d Cir. 1985); cf. Douglas Oil Co. of Ca. v. Petrol Stops NW, 441 U.S. 211, 219 (1979) (observing that grand jury secrecy is designed in part to "assure that persons who are accused

ile, attorney typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Work product 6(e)

ed secrecy; and (3) the request is structured to cover only needed materials. United States v. Moussaoui, 483 F.3d 220, 235 (4th Cir. 2007) (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 222 (1979)). 20. Portions of Exhibits 1, 2, and 3 are relevant to a judicial proceeding, that is, the Ja

I.P.COM vr-rot-hocod -0755 EFTA00277522 • • BOIES. SCHILLER & FLEXNER LLP Letter to Federal Bu

he invitation and made no submission. The court then entered an order granting the motions to co. quash. Applying the balancing test set forth in Douglas Oil Co. v. Petrol Stops Nonhwest, 441 U.S. 211, 99 S.Ct. 1667. 60 L.Ed.2d 156 (1979), the court found that the government had failed to establish a suffic

- Milt - /O qt*,1 - .2 55 EFTA01699640 • • BOIES, SCHILLER & FLEXNER LLP Letter to Federal Bur

pt the invitation and made no submission. The court then entered an order granting the motions to quash. Applying the balancing test set forth in Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 99 S.Ct. 1667, 60 L.Ed.2d 156 (1979), the court found that the government had failed to establish a suffi