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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
dant's counsel ("Defense Staff"); ii. any expert or potential expert, legal advisor, consultant, or any other individual retained or employed by the Defendant and Defense Counsel for the purpose of assisting in the defense of this case ("Defense Experts/Advisors"); iii. such other persons as hereafter may be authorized by
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
dant's counsel ("Defense Staff"); ii. any expert or potential expert, legal advisor, consultant, or any other individual retained or employed by the Defendant and Defense Counsel for the purpose of assisting in the defense of this case ("Defense Experts/Advisors"); iii. such other persons as hereafter may be authorized by
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
dant's counsel ("Defense Staff"); ii. any expert or potential expert, legal advisor, consultant, or any other individual retained or employed by the Defendant and Defense Counsel for the purpose of assisting in the defense of this case ("Defense Experts/Advisors"); iii. such other persons as hereafter may be authorized by
Entities connected to both Ragen and the Defendant and Defense Counsel

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Touhy
PERSONthe Government and Defense Counsel
ORGANIZATION
Ghislaine Maxwell
PERSONDefense Staff
ORGANIZATION
ALISON J. NATHAN
ORGANIZATIONDesignated Persons
ORGANIZATIONDefense Experts/Advisors
ORGANIZATIONHighly Confidential Information
ORGANIZATIONSouthern District
LOCATION
Southern District of New York
ORGANIZATION
James Comey
PERSON
Corley
PERSONMySpace
ORGANIZATIONAlex Rossmiller
PERSONOwn Documents
ORGANIZATIONThe Silvio J. Mollo Building
ORGANIZATION
Prince Andrew
PERSON