3
Shared Docs
3
Same-Page
3 / 3
Mentions
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
any charges in the above- captioned case, whichever date is later. 18. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree in writing otherwise, or (b) this Order is modified by further order of the Court. 19. The Government and Defense Counsel agree to
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
any charges in the above- captioned case, whichever date is later. 18. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree in writing otherwise, or (b) this Order is modified by further order of the Court. 19. The Government and Defense Counsel agree to
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
any charges in the above- captioned case, whichever date is later. 18. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree in writing otherwise, or (b) this Order is modified by further order of the Court. 19. The Government and Defense Counsel agree to
Entities connected to both Ragen and the Government and Defense Counsel

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