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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
n of the defendants in this case), all of whom are nonetheless bound by this Protective Order. 3. To the extent that Discovery is disseminated to Defense Experts/Advisors, Other Authorized Persons, or Potential Defense Witnesses, via means other than electronic mail, Defense Counsel shall encrypt and/or password prot
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
n of the defendants in this case), all of whom are nonetheless bound by this Protective Order. 3. To the extent that Discovery is disseminated to Defense Experts/Advisors, Other Authorized Persons, or Potential Defense Witnesses, via means other than electronic mail, Defense Counsel shall encrypt and/or password prot
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
n of the defendants in this case), all of whom are nonetheless bound by this Protective Order. 3. To the extent that Discovery is disseminated to Defense Experts/Advisors, Other Authorized Persons, or Potential Defense Witnesses, via means other than electronic mail, Defense Counsel shall encrypt and/or password prot
Entities connected to both Ragen and Defense Experts/Advisors

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