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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
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
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
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
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
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 Ragen and Defense Staff

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Touhy
PERSON
Geoffrey S. Berman
PERSONthe Government and Defense Counsel
ORGANIZATIONDesignated Persons
ORGANIZATIONDefense Experts/Advisors
ORGANIZATIONHighly Confidential Information
ORGANIZATIONthe Defendant and Defense Counsel
ORGANIZATION
Ghislaine Maxwell
PERSON
ALISON J. NATHAN
ORGANIZATIONSouthern District
LOCATION
Southern District of New York
ORGANIZATION
James Comey
PERSONAlex Rossmiller
PERSON
Corley
PERSON
Prince Andrew
PERSONThe Silvio J. Mollo Building
ORGANIZATIONOwn Documents
ORGANIZATION