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9/18/2020
Case 20-3061, Document 65, 09/18/2020, 2928280, Page12 of 125

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 21 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) (lnl) (Entered: 08/18/2020)

08/20/2020 45 NOTICE OF ATTORNEY APPEARANCE Lara Elizabeth Pomerantz appearing for USA.
(Pomerantz, Lara) (Entered: 08/20/2020)

https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.pl?347708277129655-L_1_0-1
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