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" individuals, by name, who have "spoken on the public record to the media or in public fora, or in litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell." Specifically, the defendant's proposed protective order differs from the Government's in that it adds a sentence, in its par
defendant's demand that she and her counsel be permitted to name any individuals who have ever publicly identified themselves as a victim of either Epstein or the defendant in any "public fora," and at any time, without limitation, is extraordinarily broad, unnecessary, and inappropriate, and should be
litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell." Specifically, the
otection of their privacy interests here than the defense proposal would afford. B. The Defendant's Demand that the Government Restrict Use of its Own Documents The defendant and her counsel also ask the Court to impose restrictions upon the Government in its use, through potential witnesses and their couns
" individuals, by name, who have "spoken on the public record to the media or in public fora, or in litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell."' Specifically, the defendant's proposed protective order differs from the Government's in that it adds a sentence, in its pa
defendant's demand that she and her counsel be permitted to name any individuals who have ever publicly identified themselves as a victim of either Epstein or the defendant in any "public fora," and at any time, without limitation, is extraordinarily broad, unnecessary, and inappropriate, and should be
litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell."' Specifically, th
otection of their privacy interests here than the defense proposal would afford. B. The Defendant's Demand that the Government Restrict Use of its Own Documents The defendant and her counsel also ask the Court to impose restrictions upon the Government in its use, through potential witnesses and their couns
" individuals, by name, who have "spoken on the public record to the media or in public fora, or in litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell."' Specifically, the defendant's proposed protective order differs from the Government's in that it adds a sentence, in its par
defendant's demand that she and her counsel be permitted to name any individuals who have ever publicly identified themselves as a victim of either Epstein or the defendant in any "public fora," and at any time, without limitation, is extraordinarily broad, unnecessary, and inappropriate, and should be
litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell."' Specifically, the
otection of their privacy interests here than the defense proposal would afford. B. The Defendant's Demand that the Government Restrict Use of its Own Documents The defendant and her counsel also ask the Court to impose restrictions upon the Government in its use, through potential witnesses and their couns
" individuals, by name, who have "spoken on the public record to the media or in public fora, or in litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell."' Specifically, the defendant's proposed protective order differs from the Government's in that it adds a sentence, in its par
defendant's demand that she and her counsel be permitted to name any individuals who have ever publicly identified themselves as a victim of either Epstein or the defendant in any "public fora," and at any time, without limitation, is extraordinarily broad, unnecessary, and inappropriate, and should be
litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell."' Specifically, the
otection of their privacy interests here than the defense proposal would afford. B. The Defendant's Demand that the Government Restrict Use of its Own Documents The defendant and her counsel also ask the Court to impose restrictions upon the Government in its use, through potential witnesses and their couns
" individuals, by name, who have "spoken on the public record to the media or in public fora, or in litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell."' Specifically, the defendant's proposed protective order differs from the Government's in that it adds a sentence, in its pa
defendant's demand that she and her counsel be permitted to name any individuals who have ever publicly identified themselves as a victim of either Epstein or the defendant in any "public fora," and at any time, without limitation, is extraordinarily broad, unnecessary, and inappropriate, and should be
litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell."' Specifically, th
otection of their privacy interests here than the defense proposal would afford. B. The Defendant's Demand that the Government Restrict Use of its Own Documents The defendant and her counsel also ask the Court to impose restrictions upon the Government in its use, through potential witnesses and their couns
" individuals, by name, who have "spoken on the public record to the media or in public fora, or in litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell."' Specifically, the defendant's proposed protective order differs from the Government's in that it adds a sentence, in its par
defendant's demand that she and her counsel be permitted to name any individuals who have ever publicly identified themselves as a victim of either Epstein or the defendant in any "public fora," and at any time, without limitation, is extraordinarily broad, unnecessary, and inappropriate, and should be
litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell."' Specifically, the
otection of their privacy interests here than the defense proposal would afford. B. The Defendant's Demand that the Government Restrict Use of its Own Documents The defendant and her counsel also ask the Court to impose restrictions upon the Government in its use, through potential witnesses and their couns
Entities connected to both Jeffrey Epstein and Own Documents

Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONSouthern District
LOCATION
Department of Justice
ORGANIZATION
Southern District of New York
ORGANIZATION
James Comey
PERSON
Touhy
PERSONMySpace
ORGANIZATIONThe Silvio J. Mollo Building
ORGANIZATIONRagen
PERSON
ALISON J. NATHAN
ORGANIZATION
Corley
PERSONAlex Rossmiller
PERSONDefense Staff
ORGANIZATIONthe Government and Defense Counsel
ORGANIZATIONDesignated Persons
ORGANIZATIONDefense Experts/Advisors
ORGANIZATIONHighly Confidential Information
ORGANIZATIONthe Defendant and Defense Counsel
ORGANIZATION