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Case 21-58, Document 23, 03/29/2021, 3065988, Page10 of 24

statement might have occurred decades ago and have no relevance to the charges in
this case. These individuals still maintain a significant privacy interest that must be
safeguarded. The exception the Defense seeks is too broad and risks undermining the
protections of the privacy of witnesses and alleged victims that is required by law. In
contrast, the Government's proffered language would allow Ms. Maxwell to publicly
reference individuals who have spoken by name on the record in this case. It also
allows the Defense to "referenc[e] the identities of individuals they believe may be
relevant... to Potential Defense Witnesses and their counsel during the course of the
investigation and preparation of the defense case at trial." Dkt. No. 33-1, 5. This
proposal adequately balances the interests at stake. And as the Government's letter
notes, see Dkt. No. 33 at 4, to the extent that the Defense needs an exception to the
protective order for a specific investigative purpose, they can make applications to the
Court on a case-by-case basis. Second, restrictions on the ability of potential
witnesses and their counsel to use discovery materials for purposes other than
preparing for trial in this case are unwarranted. The request appears unprecedented
despite the fact that there have been many high-profile criminal matters that had
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
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 | 40 | 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 | 43 | 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 | 44 | 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

DOJ-OGR-00019805