EFTA00026750.pdf

"United States v. Gleislaine Maxwell, 20 Cr. 330 (AJN)"

"The Government respectfully submits this letter with respect to the protective order to be entered in the above-captioned case"

"The Government respectfully submits this letter with respect to the protective order to be entered in the above-captioned case"

"The Government respectfully submits this letter with respect to the protective order to be entered in the above-captioned case"

"criminal case against Ghislaine Maxwell subject to extraordinary public attention and scrutiny"

"The protective order in the Epstein case included a provision stating that it did not prohibit defense counsel from publicly referencing individuals"

"The Honorable Alison J. Nathan July 28, 2020 Page 4 Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20"

"The Government's submission proposes that the defendant and her counsel not be precluded from discussing publicly individuals who identify themselves "

"defense counsel for why it would be appropriate or necessary to publicly name victims ... as the defendant presumably would have it"

"GHISLAINE MAXWELL, Defendant."

"ALISON J. NATHAN, United States District Judge"

"Alex Rossmiller ... Assistant United States Attorneys"

"Alison Moe ... Assistant United States Attorneys"

"Maurene Comey ... Assistant United States Attorneys"

"Alex Rossmiller ... Assistant United States Attorneys Southern District of New York"

"policies of the Department of Justice and the U.S. Attorney's Office for the Southern District of New York"

"involved in the representation of the defendants in this case"

"The Defendant and her counsel need not obtain signatures from any member of the defense team"

"appropriate officials of the Bureau of Prisons (BOP), who shall provide the defendant with electronic access to the Discovery, including Confidential "

"obtained by the Defendant or her Defense Counsel from a source other than the Government"

"HONORABLE ALISON J. NATHAN United States District Judge"

"unless authorized by the Government in writing or by Order of the Court"

"HONORABLE ALISON J. NATHAN United States District Judge"

"obtained by the Defendant or her Defense Counsel"

"Dated: New York, New York , 2020"

"The Government and defense counsel have conferred regarding a protective order several times via telephone and email between July 9, 2020, and today"

"Despite the Government's requests for clarity on the need for the defendant's requested modification, the sole additional reason provided by defense c"

"publicly referenc[e] individuals, by name, who have spoken on the public record to the media or in public fora, or in litigation — criminal or otherwi"

"many more victims have made public statements about their victimization at the hands of Epstein"

"The victims of Ghislaine Maxwell and Jeffrey Epstein have suffered enough"

"victim of Jeffrey Epstein or Ghislaine Maxwell"

"REY STRAUSS ng United States Attorney"

"the Government can represent that the Department of Justice has received both FOIA and Touhy requests in connection with this investigation"

"Copies of Discovery or other materials produced by the Government in this action bearing confidential stamps"

"Case 1:20-cr-00330-AJN"

"Copies of Discovery or other materials produced by the Government in this action bearing confidential stamps"