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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
any charges in the above- captioned case, whichever date is later. 18. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree in writing otherwise, or (b) this Order is modified by further order of the Court. 19. The Government and Defense Counsel agree to
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
any charges in the above- captioned case, whichever date is later. 18. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree in writing otherwise, or (b) this Order is modified by further order of the Court. 19. The Government and Defense Counsel agree to
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
any charges in the above- captioned case, whichever date is later. 18. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree in writing otherwise, or (b) this Order is modified by further order of the Court. 19. The Government and Defense Counsel agree to
Entities connected to both Touhy and the Government and Defense Counsel

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