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ple, the Government has obligations under various statutory and regulatory regimes, including but not limited to the Freedom of Information Act and Touhy v. Ragen, 340 U.S. 462 (1951), that cannot be bargained away through a protective order. Indeed, the Government can represent that the Department of
Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 1 of 7 U.S. Department of Justice United Stales Attorney Southern District of New York The Silvio J. Mollo Building One saint Andrew's Plaza New York. New York 10007 July 28, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern D
cannot be bargained away through a protective order. Indeed, the Government can represent that the Department of Justice has received both FOIA and Touhy requests in connection with this investigation, requests to which the Department has a legal obligation to respond appropriately. The Government res
Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 1 of 7 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 28, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern D
ple, the Government has obligations under various statutory and regulatory regimes, including but not limited to the Freedom of Information Act and Touhy v. Ragen, 340 U.S. 462 (1951), that cannot be bargained away through a protective order. Indeed, the Government can represent that the Department of
Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 1 of 7 U.S. Department of Justice United Stales Attorney Southern District of New York The Silvio J. Mollo Building One saint Andrew's Plaza New York. New York 10007 July 28, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern D
ple, the Government has obligations under various statutory and regulatory regimes, including but not limited to the Freedom of Information Act and Touhy v. Ragen, 340 U.S. 462 (1951), that cannot be bargained away through a protective order. Indeed, the Government can represent that the Department of
Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 1 of 7 U.S. Department of Justice United Stales Attorney Southern District of New York The Silvio J. Mollo Building One saint Andrew's Plaza New York. New York 10007 July 28, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern D
Entities connected to both Touhy and The Silvio J. Mollo Building

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
Geoffrey S. Berman
PERSON
United States
LOCATIONSouthern District
LOCATION
New York
LOCATION
Audrey Strauss
PERSONRagen
PERSON
George Mitchell
PERSONFBI
ORGANIZATIONJane Doe
PERSON
Alfredo Rodriguez
PERSON
Michael Cohen
PERSON
Southern District of New York
ORGANIZATIONMartin Weinberg
PERSONCity of New York
LOCATION
Reid Weingarten
PERSON