Epstein Secrets

ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter with respect to the protective order to be entered in the abo

. PROPOSED] PROTECTIVE ORDER 20 Cr. 330 (AJN) x ALISON J. NATHAN, United States District Judge: WHEREAS the Government intends to produce to GHISLAINE MAXWELL, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prem

] PROTECTIVE ORDER 20 Cr. 330 (AJN) x ALISON J. NATHAN, United States District Judge: WHEREAS the Government intends to produce to GHISLAINE MAXWELL, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prematurely d

Government has obligations under various statutory and regulatory regimes, including but not limited to the Freedom of Information Act and Touhy v. Ragen, 340 U.S. 462 (1951), that cannot be bargained away through a protective order. Indeed, the Government can represent that the Department of Justice

ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter with respect to the protective order to be entered in the abo

. PROPOSED] PROTECTIVE ORDER 20 Cr. 330 (AJN) x ALISON J. NATHAN, United States District Judge: WHEREAS the Government intends to produce to GHISLAINE MAXWELL, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prem

] PROTECTIVE ORDER 20 Cr. 330 (AJN) x ALISON J. NATHAN, United States District Judge: WHEREAS the Government intends to produce to GHISLAINE MAXWELL, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prematurely d

Government has obligations under various statutory and regulatory regimes, including but not limited to the Freedom of Information Act and Touhy v. Ragen, 340 U.S. 462 (1951), that cannot be bargained away through a protective order. Indeed, the Government can represent that the Department of Justice

ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter with respect to the protective order to be entered in the abo

. PROPOSED] PROTECTIVE ORDER 20 Cr. 330 (AJN) x ALISON J. NATHAN, United States District Judge: WHEREAS the Government intends to produce to GHISLAINE MAXWELL, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prem

] PROTECTIVE ORDER 20 Cr. 330 (AJN) x ALISON J. NATHAN, United States District Judge: WHEREAS the Government intends to produce to GHISLAINE MAXWELL, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prematurely d

Government has obligations under various statutory and regulatory regimes, including but not limited to the Freedom of Information Act and Touhy v. Ragen, 340 U.S. 462 (1951), that cannot be bargained away through a protective order. Indeed, the Government can represent that the Department of Justice