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t initial production is nonsense. As the Court is aware, the EFTA00040543 Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 2 of 5 Honorable Alison J. Nathan August 13, 2020 Page 2 protective order was docketed on Friday, July 31, 2020'—the timing of which was principally the result of the defendant's
urportedly had received "critical new information" from the criminal case that it could not disclose "because it is subject to a protective order in the Criminal Action," and further noting publicly a desire to seek modification of the protective order in thi use such materials in the civil case, which the protect
legal arguments—more than four months in advance of the deadline for any such motion—relating to the ages of the victims. EFTA00077274 Honorable Alison J. Nathan August 13, 2020 Page 3 ordered disclosure of a certain victim identity shortly after the indictment, the Court noted that the Government had alre
urportedly had received "critical new information" from the criminal case that it could not disclose "because it is subject to a protective order in the Criminal Action," and further noting publicly a desire to seek modification of the protective order in this case to use such materials in the civil case, which the
t initial production is nonsense. As the Court is aware, the EFTA00084837 Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 2 of 5 Honorable Alison J. Nathan August 13, 2020 Page 2 protective order was docketed on Friday, July 31, 2020'—the timing of which was principally the result of the defendant's
urportedly had received "critical new information" from the criminal case that it could not disclose "because it is subject to a protective order in the Criminal Action," and further noting publicly a desire to seek modification of the protective order in this') use such materials in the civil case, which the prot
Entities connected to both Alison J. Nathan and the Criminal Action

Ghislaine Maxwell
PERSON
Prince Andrew
PERSONLaura Menninger
PERSONSecond Circuit
ORGANIZATION
Department of Justice
ORGANIZATIONSouthern District
LOCATION
Denver
LOCATION
Colorado
LOCATIONFederal Bureau of Prisons
ORGANIZATIONThompson
PERSONLoretta A. Preska
PERSONMahabub
PERSONthe Defense Letter
ORGANIZATIONthe Court Dictate the Conditions of Her Confinement
ORGANIZATIONthe Second Circuit's
ORGANIZATIONThe Silvio J. Mob Building
ORGANIZATION
Foreman
PERSON