Epstein Secrets

That is the definition. 24 However, I'm also going to ask the parties to agree 25 upon an order that would expand the confidentiality agreement SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00076418 Case 20-2413, Document 44. 08/20/2020, 2913556, Page37 of 78 App.-0811 7 G4LMGIUC 1 to this exte

cole Simmons 2 EFTA00076390 Case Gaga4.407741333-IDARn-Offiuhiefle3MOQIXD, Filki5B33fface9:4191;91 of 4 App.-0783 United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. NON-REDACTED DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF

ll provide a copy of this Order to any Designated Persons to whom they disclose Discovery materials. Prior to disclosure of Discovery materials to Designated Persons, any such Designated Person shall agree to be subject to the terms of this Order by signing a copy hereof and stating that they "Agree to be bound

Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 1 of 7 U.S. Department of Justice United Stales Attorney Southern District of New York The Silvio J. Mollo Building One saint Andrew's Plaza New York. New York 10007 July 28, 2020 VIA ECF The Honorable Alison J. Nathan

ll provide a copy of this Order to any Designated Persons to whom they disclose Discovery materials. Prior to disclosure of Discovery materials to Designated Persons, any such Designated Person shall agree to be subject to the terms of this Order by signing a copy hereof and stating that they "Agree to be bound

9 New York, New York apA pi Nati` s4 :Remo HONORABLE RICHARD M. BERMAN United States District Judge GEOFFREY S. BERMAN united States Attorney Southern District of New York By: /s/ Dated: -LIN as, 2019 New York, New York Assistant United States Attorneys JEFFREY EPSTEIN BY: ?g7--Ca g al-e/75 Martin W

ot be possessed outside the presence of Defense Counsel, or maintained, by the Defendant; e) may be disclosed only by Defense Counsel and only to Designated Persons; f) may be shown to, but not disseminated to or provided copies of to, Potential Witnesses, to the extent deemed 5 EFTA00102039 Case 1:19-cr-0

2019 New York, New York riatre4R s%ftna l t HONORABLE RICHARD M. BERMAN United States District Judge GEOFFREY S. BERMAN united States Attorney Southern District of New York By: /6/ Dated: -sulm as, 2019 New York, New York Assistant United States Attorneys JEFFREY EPSTEIN ielliC/ Martin Weinberg, Esq.

ot be possessed outside the presence of Defense Counsel, or maintained, by the Defendant; e) may be disclosed only by Defense Counsel and only to Designated Persons; f) May be shown to, but not disseminated to or provided copies of to, Potential Witnesses, to the extent deemed EFTA00164838 Case 1:19-cr-0049

Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 1 of 7 U.S. Department of Justice United Stales Attorney Southern District of New York The Silvio J. Mollo Building One saint Andrew's Plaza New York. New York 10007 July 28, 2020 VIA ECF The Honorable Alison J. Nathan

ll provide a copy of this Order to any Designated Persons to whom they disclose Discovery materials. Prior to disclosure of Discovery materials to Designated Persons, any such Designated Person shall agree to be subject to the terms of this Order by signing a copy hereof and stating that they "Agree to be bound

Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 1 of 7 U.S. Department of Justice United Stales Attorney Southern District of New York The Silvio J. Mollo Building One saint Andrew's Plaza New York. New York 10007 July 28, 2020 VIA ECF The Honorable Alison J. Nathan

ll provide a copy of this Order to any Designated Persons to whom they disclose Discovery materials. Prior to disclosure of Discovery materials to Designated Persons, any such Designated Person shall agree to be subject to the terms of this Order by signing a copy hereof and stating that they "Agree to be bound