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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
ailable medium. 5. The Government (other than in the discharge of their professional obligations in this matter), the Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses and their counsel, and Other Authorized Persons are strictly prohibited from publicly 4 EF
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
ailable medium. 5. The Government (other than in the discharge of their professional obligations in this matter), the Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses and their counsel, and Other Authorized Persons are strictly prohibited from publicly 4 EF
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
ailable medium. 5. The Government (other than in the discharge of their professional obligations in this matter), the Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses and their counsel, and Other Authorized Persons are strictly prohibited from publicly 4 EF
Entities connected to both Touhy and Defense Staff

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSON
United States
LOCATIONRagen
PERSON
Geoffrey S. Berman
PERSONSouthern District
LOCATIONMartin Weinberg
PERSONthe Government and Defense Counsel
ORGANIZATION
Reid Weingarten
PERSONDesignated Persons
ORGANIZATIONDefense Experts/Advisors
ORGANIZATION
Harry Reid
PERSONHighly Confidential Information
ORGANIZATIONthe Defendant and Defense Counsel
ORGANIZATION
ALISON J. NATHAN
ORGANIZATION
Southern District of New York
ORGANIZATION
Prince Andrew
PERSON
James Comey
PERSONOwn Documents
ORGANIZATION