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o unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "A in connection w
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
o unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "A in connection wi
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
o unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "Application"), in c
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
States Code, Section 1651, for an order relieving Boies Schiller & Flexner LLP (the "Law Firm") of its o
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
o unseal discovery materials in the possession of Boies Schiller & Flexner LLP the "A in connection wit
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
States Code, Section 1651, for an order relieving Boies Schiller & Flexner LLP (the "Law Finn") of its o
Page: EFTA00029951 →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
Page: EFTA00029952 →Entities connected to both David Boies and International Tel

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Virginia Giuffre
PERSONthe Southern District
LOCATIONJane Doe
PERSONSouthern District
LOCATION
George W. Bush
PERSON
Boies Schiller
ORGANIZATION
Department of Justice
ORGANIZATION
Southern District of New York
ORGANIZATION
Stephen Hawking
PERSONSecond Circuit
ORGANIZATION
Woody Allen
PERSONSweet
PERSONMartindell
PERSON
Bill Richardson
PERSONChemical Bank
ORGANIZATION
Boies Schiller & Flexner LLP
ORGANIZATIONFisher
PERSON