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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
otection of their privacy interests here than the defense proposal would afford. B. The Defendant's Demand that the Government Restrict Use of its Own Documents The defendant and her counsel also ask the Court to impose restrictions upon the Government in its use, through potential witnesses and their couns
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
otection of their privacy interests here than the defense proposal would afford. B. The Defendant's Demand that the Government Restrict Use of its Own Documents The defendant and her counsel also ask the Court to impose restrictions upon the Government in its use, through potential witnesses and their couns
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
otection of their privacy interests here than the defense proposal would afford. B. The Defendant's Demand that the Government Restrict Use of its Own Documents The defendant and her counsel also ask the Court to impose restrictions upon the Government in its use, through potential witnesses and their couns
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
otection of their privacy interests here than the defense proposal would afford. B. The Defendant's Demand that the Government Restrict Use of its Own Documents The defendant and her counsel also ask the Court to impose restrictions upon the Government in its use, through potential witnesses and their couns
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
otection of their privacy interests here than the defense proposal would afford. B. The Defendant's Demand that the Government Restrict Use of its Own Documents The defendant and her counsel also ask the Court to impose restrictions upon the Government in its use, through potential witnesses and their couns
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
otection of their privacy interests here than the defense proposal would afford. B. The Defendant's Demand that the Government Restrict Use of its Own Documents The defendant and her counsel also ask the Court to impose restrictions upon the Government in its use, through potential witnesses and their couns
Entities connected to both Touhy and Own Documents

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Ghislaine Maxwell
PERSONRagen
PERSONSouthern District
LOCATION
Southern District of New York
ORGANIZATION
Prince Andrew
PERSON
Corley
PERSONMySpace
ORGANIZATION
James Comey
PERSONThe Silvio J. Mollo Building
ORGANIZATIONDefense Staff
ORGANIZATIONAlex Rossmiller
PERSON
ALISON J. NATHAN
ORGANIZATIONthe Defendant and Defense Counsel
ORGANIZATIONDesignated Persons
ORGANIZATIONDefense Experts/Advisors
ORGANIZATIONHighly Confidential Information
ORGANIZATIONthe Government and Defense Counsel
ORGANIZATION