EPSTEIN
page 9 / 1479 . OCR, unverified
related civil litigation. The Government labors under many restrictions including Rule
6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and other
policies of the Department of Justice and the U.S. Attorney's Office for the Southern
District of New York, all of which the Court expects the Government to scrupulously
follow. Furthermore, the Government indicates that it will likely only provide potential
witnesses with materials that those witnesses already have in their possession. See Dkt.
No. 33 at 6. And of course, those witnesses who do testify at trial would be subject to
examination on the record as to what materials were provided or shown to them by the
Government. Nothing in the Defense's papers explains how its unprecedented
proposed restriction is somehow necessary to ensure a fair trial. For the foregoing
reasons, the Court adopts the Government's proposed protective order, which will be
DOJ-OGR- 00020397
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Case 22-1426, Document 1-2, 07/08/2022, 3344417, Page12 of 91
entered on the docket. This resolves Dkt. No. 29. SO ORDERED. (Signed by Judge
Alison J. Nathan on 7/30/2020)(bw) (Entered: 07/31/2020)
08/10/2020 / 38 / LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated August 10, 2020 re: Discovery Disclosure and Access . Document filed by
Ghislaine Maxwell. (Everdell, Christian) (Entered: 08/10/2020)
08/10/2020 / 39 / AFFIDAVIT of Christian R. Everdell by Ghislaine Maxwell. (Everdell, Christian)
(Entered: 08/10/2020)
08/11/2020 Q / MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 38 LETTER MOTION
addressed to Judge Alison J. Nathan from Christian R. Everdell dated August 10, 2020
re: Discovery Disclosure and Access. ENDORSEMENT: The Government is hereby
ORDERED to respond to the Defendant's letter motion by Thursday, August 13, 2020.
The Defendant's reply, if any, is due on or before Monday, August 17, 2020.
(Responses due by 8/13/2020. Replies due by 8/17/2020) (Signed by Judge Alison J.
Nathan on 8/11/2020) (ap) (Entered: 08/11/2020)
08/13/2020 / 41 / LETTER RESPONSE in Opposition by USA as to Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Alex Rossmiller dated August 13, 2020 re: 38 LETTER
MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated
August 10, 2020 re: Discovery Disclosure and Access .. (Rossmiller, Alex) (Entered:
08/13/2020)
08/17/2020 / 42 / LETTER REPLY TO RESPONSE to Motion by Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Christian R. Everdell dated August 17, 2020 re 38
LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell
dated August 10, 2020 re: Discovery Disclosure and Access .. (Everdell, Christian)
(Entered: 08/17/2020)
08/17/2020 3 / LETTER MOTION addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca
dated August 17, 2020 re: Request for Permission to Submit Letter Motion in Excess
of Three Pages . Document filed by Ghislaine Maxwell. (Pagliuca, Jeffrey) (Entered:
08/17/2020)
08/18/2020 4 / ORDER as to Ghislaine Maxwell: On August 17, 2020, the Defendant filed a letter
motion seeking a modification of this Court's Protective Order, which the Court
entered on July 30, 2020. Defendant also moves to file that letter motion under seal.
The Governments opposition to Defendant's letter motion is hereby due Friday, August
at 12 p.m. The Defendant's reply is due on Monday, August 24 at 12 p.m. The
parties shall propose redactions to the letter briefing on this issue. Alternatively, the
parties shall provide support and argument for why the letter motions should be sealed
in their entirety. SO ORDERED. (Responses due by 8/21/2020. Replies due by
8/24/2020.) (Signed by Judge Alison J. Nathan on 8/18/2020) (nl) (Entered:
08/18/2020)
SEALED DOCUMENT placed in vault. (mhe) (Entered: 08/27/2020)
17, 2020 re: Request for Permission to Submit Letter Motion in Excess of Three Pages
(Rossmiller, Alex) (Entered: 08/21/2020)
08/21/2020 / 46 / LETTER RESPONSE in Opposition by USA as to Ghislaine Maxwell addressed to
Judge Alison J. Nathan from Maurene Comey dated August 21, 2020 re: 43 LETTER
.. (Rossmiller, Alex) (Entered: 08/21/2020)
08/24/2020 / 48 / LETTER MOTION addressed to Judge Alison J. Nathan from Laura A. Menninger
dated August 24, 2020 re: Request to File Under Seal: Proposed Redactions to Request
to Modify Protective Order and Reply in Support Thereof . Document filed by
08/20/2020 NOTICE OF ATTORNEY APPEARANCE Lara Elizabeth Pomerantz appearing for
USA. (Pomerantz, Lara) (Entered: 08/20/2020)
MOTION addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca dated August
08/21/2020 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
Maurene Comey dated August 21, 2020 re: Proposed redactions to letter briefing, in