This document is page 2 of a Protective Order filed on December 16, 2019, in the criminal case against Tova Noel and Michael Thomas (the guards on duty when Jeffrey Epstein died). The order outlines restrictions on 'Protected Materials' provided during discovery, stipulating they can only be used for defense purposes and cannot be disclosed to third parties except as specifically allowed. The defendants consented to this order.
| Name | Role | Context |
|---|---|---|
| Tova Noel | Defendant |
Consented to the entry of the Order through counsel
|
| Michael Thomas | Defendant |
Consented to the entry of the Order through counsel
|
| Name | Type | Context |
|---|---|---|
| The Government |
Demonstrated good cause for relief; designates 'Protected Materials'
|
|
| Department of Justice |
Indicated by footer 'DOJ-OGR'
|
|
| Federal Court |
Implied by Case Header and Federal Rules citation
|
"WHEREAS, TOVA NOEL and MICHAEL THOMAS, the defendants, by and through their respective counsel of record, consent to the entry of this Order"Source
"Discovery materials designated as 'Protected Materials' by the Government may be used by the defendants... only for purposes of defending the charges"Source
"The Protected Materials... Shall not be disclosed in any form by the Defense to any third party"Source
Complete text extracted from the document (1,280 characters)
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