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Case 1:20-cr-00330-AJN Document 52 Filed 09/02/20 Page 3 of 5

case in other civil proceedings. She bases her request on the premise that disclosure of the
Documents to the relevant judicial officers is allegedly necessary to ensure the fair adjudication
of issues being litigated in those civil matters. But after fourteen single-spaced pages of heated
rhetoric, the Defendant proffers no more than vague, speculative, and conclusory assertions as to
why that is the case. She provides no coherent explanation of what argument she intends to
make before those courts that requires the presentation of the materials received in discovery in
this criminal matter under the existing terms of the protective order in this case. And she
furnishes no substantive explanation regarding the relevance of the Documents to decisions to be
made in those matters, let alone any explanation of why modifying the protective order in order
to allow such disclosure is necessary to ensure the fair adjudication of those matters. In sum, the
arguments the Defendant presents to the Court plainly fail to establish good cause. The
Defendant’s request is DENIED on this basis.

Indeed, good cause for the requested modification of the protective order is further
lacking because, as far as this Court can discern, the facts she is interested in conveying to the
judicial decisionmakers in the Civil Cases are already publicly available, including in the
Government’s docketed letter on this issue. See Dkt. No. 46. In the opening paragraph of her
reply letter dated August 24, 2020, the Defendant states that she is essentially seeking to disclose
under seal to certain judicial officers the following factual information:

1. Grand jury subpoenas were issued to an entity (“Recipient”) after the Government
opened a grand jury investigation into Jeffrey Epstein and his possible co-
conspirators;

2. The Recipient concluded that it could not turn over materials responsive to the grand
jury subpoena absent a modification of the civil protective orders in the civil cases;

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