EFTA01251062Set 9
53p13,167w
such, I am a "federal law enforcement officer" within the
meaning of Federal Rule of Criminal Procedure 41(a)(2XC), that is, a government agent engaged
in enforcing the criminal ... U.S.C.
§§ 2703(c) and (c)(1)(A) and the applicable procedures of Federal Rule of Criminal Procedure 41;
2019.07.24
SDNY_GM_00000565
CONFIDENTIAL
EFTA_00114649
EFTA01251069
18 U.S.C ... such, I am a "federal law enforcement officer" within the
meaning of Federal Rule of Criminal Procedure 41(a)(2XC), that is, a government agent engaged
in enforcing the criminal
https://www.justice.gov/epstein/files/DataSet%209/EFTA01251062.pdf
EFTA00582787Set 9
2015-01-2120p4,919w
these settlement communications was unnecessary or
inappropriate.
I. THE LAW
During discovery, pursuant to Federal Rule of Civil Procedure 26(c), the Court may
enter a protective order to prevent ... discovery material is subject to the discretion of the trial court and
the federal rules that circumscribe that discretion. Where discovery materials are concerned, the
constitutional right of access standard ... identical to that ofRule 26(c) of the Federal Rules ofCivil
Procedure.@ Chicago Tribune Co. v. Bridgestone/Firestone Inc., 263 F.3d 1304, 1310 (11th Cir.
2001). Accordingly, Awhere a third party
https://www.justice.gov/epstein/files/DataSet%209/EFTA00582787.pdf
EFTA00027654Set 8
2021-11-101p172w
conference is scheduled for November 10, 2021 to address the Defendant's motion
under Federal Rule of Evidence 412, Dkt. No. 378, the Defendant's motion in limine to exclude ... under Federal Rule of Evidence 702 and Daubert v. Merrell Dow Pharmaceuticals, Inc., 509
U.S. 579 (1993), Dkt. No. 386, and the other outstanding issues that overlap with these
https://www.justice.gov/epstein/files/DataSet%208/EFTA00027654.pdf