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

any charges in the above- captioned case, whichever date is later. 18. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree in writing otherwise, or (b) this Order is modified by further order of the Court. 19. The Government and Defense Counsel agree to

" 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

any charges in the above- captioned case, whichever date is later. 18. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree in writing otherwise, or (b) this Order is modified by further order of the Court. 19. The Government and Defense Counsel agree to

" 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

any charges in the above- captioned case, whichever date is later. 18. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree in writing otherwise, or (b) this Order is modified by further order of the Court. 19. The Government and Defense Counsel agree to

" 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

any charges in the above- captioned case, whichever date is later. 18. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree in writing otherwise, or (b) this Order is modified by further order of the Court. 19. The Government and Defense Counsel agree to

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

9 Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 9 of 9 13. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree otherwise, or (b) this Order is modified by further order of the Court. SO ORDERED: Dated: New York, New York Pt, 2019 AGREED A

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

5 Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 9 of 9 13. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree otherwise, or (b) this Order is modified by further order of the Court. SO ORDERED: Dated: New York, New York air, 261g AGREED