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

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

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

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

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

h do not apply to communications exclusively between and among Defense Counsel. 3. The Government, the Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Witnesses, and Other Authorized Persons are prohibited from posting or causing to be posted any of the Discovery or information contain

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.

nesses"), to the extent deemed necessary by defense counsel, for trial preparation. 2. To the extent the Discovery is disclosed to Defense Staff, Defense Experts/Advisors, Other Authorized Persons, or Potential Witnesses, Defense Counsel shall instruct such individual(s) of the terms of this Order and that such indi

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

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

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

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