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he Court should enter the Government's proposed protective order, which is enclosed, and deny the defendant's motion. Respectfully submitted, By: Alex Rossmiller / Alison Moe / Maurene Comey Assistant United States Attorneys Southern District of New York Tel: (212) 637-2415 REY STRAUSS ng United States At
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
he Court should enter the Government's proposed protective order, which is enclosed, and deny the defendant's motion. Respectfully submitted, By: Alex Rossmiller / Alison Moe / Maurene Comey Assistant United States Attorneys Southern District of New York Tel: (212) 637-2415 REY STRAUSS ng United States At
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
he Court should enter the Government's proposed protective order, which is enclosed, and deny the defendant's motion. Respectfully submitted, By: Alex Rossmiller / Alison Moe / Maurene Comey Assistant United States Attorneys Southern District of New York Tel: (212) 637-2415 REY STRAUSS ng United States At
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 Alex Rossmiller and Defense Experts/Advisors

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
Prince Andrew
PERSON
James Comey
PERSONDefense Staff
ORGANIZATIONthe Government and Defense Counsel
ORGANIZATIONSouthern District
LOCATIONDesignated Persons
ORGANIZATION
United States
LOCATIONHighly Confidential Information
ORGANIZATION
Department of Justice
ORGANIZATIONthe Defendant and Defense Counsel
ORGANIZATION
ALISON J. NATHAN
ORGANIZATION
Southern District of New York
ORGANIZATIONThe Silvio J. Mollo Building
ORGANIZATION
Reid Weingarten
PERSON
Geoffrey S. Berman
PERSON
Corley
PERSONRagen
PERSONOwn Documents
ORGANIZATION