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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 Justice
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
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 Justice
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
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 Justice
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 Ragen and The Silvio J. Mollo Building

Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Jeffrey Epstein
PERSONthe Southern District
LOCATION
Ghislaine Maxwell
PERSON
United States
LOCATION
Geoffrey S. Berman
PERSONSouthern District
LOCATION
Audrey Strauss
PERSON
New York
LOCATION
Touhy
PERSON
George Mitchell
PERSON
Alfredo Rodriguez
PERSONCity of New York
LOCATIONFBI
ORGANIZATION
Southern District of New York
ORGANIZATIONJane Doe
PERSON
James Comey
PERSONAlex Rossmiller
PERSON
ALISON J. NATHAN
ORGANIZATION