Epstein Secrets

44, 08/20/2020, 2913556, Pagel of 78 20-2413 United States Court of Appeals for the Second Circuit —against— GHISLAINE MAXWELL, SHARON CHURCHER, JEFFREY EPSTEIN, PlaintiffiAppellee, Defendant-Appellant, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNO

3, Document 44. 08/20/2020, 2913556, Page42 of 78 App.-0816 12 G4LMGIUC 1 four individuals had sexually abused her prior to ever meeting 2 Mr. Epstein. 3 If she has evidence that she already was suffering 4 from depression or some type of mental health disorder before 5 meeting our client, Ms.

t —against— GHISLAINE MAXWELL, SHARON CHURCHER, JEFFREY EPSTEIN, PlaintiffiAppellee, Defendant-Appellan

had sexually abused her prior to ever meeting 2 Mr. Epstein. 3 If she has evidence that she already was suf

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

" 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

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

" 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

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

" 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

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

FILED:a 014 PROTECTIVE ORDER 19 Cr. 490 (RMB) x RICHARD M. BERMAN, United States District Judge: WHEREAS the Government intends to produce to JEFFREY EPSTEIN, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prematurely d

CT OF NEW YORK UNITED STATES OF AMERICA JEFFREY EPSTEIN, Defendant. X USDC SONY DOCUMENT ELECTRONICA

N DISTRICT OF NEW YORK UNITED STATES OF AMERICA JEFFREY EPSTEIN, Defendant. X USDC SONY DOCUMENT ELE

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

CT OF NEW YORK UNITED STATES OF AMERICA JEFFREY EPSTEIN, Defendant. x USDC SDNY DOCUMENT ELECTRONICA

N DISTRICT OF NEW YORK UNITED STATES OF AMERICA JEFFREY EPSTEIN, Defendant. x USDC SDNY DOCUMENT ELE

ILED: S7 614 PROTECTIVE ORDER 19 Cr. 490 (RMB) x RICHARD M. BERMAN, United States District Judge: WHEREAS the Government intends to produce to JEFFREY EPSTEIN, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prematurely d

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