in question). The remedy for any resulting over-breadth in protective measures, of course, is a motion to unseal the discovery materials at issue. Indeed, the Court made this very point at the November 10, 2009 hearing. {See 11/10/2009 Hearing Tr. at 23.) Tellingly, no party or witness has brought such a motion to date, despite the parties’ and witnesses’ superior knowledge of exactly what transpired at each deposition and the testimony each witness has given. Since the Free Press, like the Court, lacks this information, it can do no more than speculate that the disclosure of a given deposition transcript would not pose any risk of undue interference with an ongoing criminal investigation. This is not sufficient to overcome a finding of good cause. See Phillips, 307 F.3d at 1213 (<HOLDING>); see also Knoll, 176 F.3d at 365 (placing the
holding that the government must provide the party seeking disclosure with a detailed index describing the documents the government claims are exempt from disclosure under foia holding that once a court has found good cause to protect material from public disclosure there is no longer any commonlaw right of access to this material and the party seeking disclosure must present sufficiently compelling reasons why the sealed discovery document should be released holding that where an authorized disclosure is voluntarily made to a nonfederal party whether or not that disclosure is denominated confidential the government waives any claim that the information is exempt from disclosure under the deliberative process privilege holding proponent of a motion for continuance should state what specific discovery is material and show why it is material holding that the disclosure is a public disclosure within the meaning of the fca if the the prior public disclosure  contained enough information to enable the government to pursue an investigation against the defendant