Subject:

Court Filing: 20cr833 (D.N.J. filed 11/18/20)

This court filing outlines the procedures for the defendant and defense counsel to access and handle discovery materials marked as 'highly confidential' by the government. It restricts the dissemination and copying of such materials and requires designated persons and potential defense witnesses to sign an order acknowledging the confidentiality obligations. The order aims to balance the defendant's right to prepare for trial with the need to protect sensitive information.

Case 1:20-cr-00330-AJN Document 37 Filed 07/30/20 177uja-1-44

Case 1:20-cr-00330-AJN Document 37 Filed 07/30/20 177uja-1-44 1M. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0. DATE FILED:7/30/2020 20-CR-330 (MN) MEMORANDUM OPINION & ORDER ALISON J. NATHAN, District Judge: Both parties have asked for the Court to enter a protective order. While they agree on most of the language, two areas of dispute have emerged. First, Ms. Maxwell seeks language allowing her to publicly reference alleged victims or witnesses who have spoken on the public record to the media or in public fora, or in litigation relating to Ms. Maxwell or Jeffrey Epstein. Second, Ms. Maxwell seeks language restricting potential Government witnesses and their counsel from using discovery materials for any purpose other than preparing for the criminal trial in this action. The Government has proposed contrary language on both of these issues. For

Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 P

Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 P UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA GHISLAINE MAXWELL, Defendant. x 1nf19 WO USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED:7/30/2020 PROTECTIVE ORDER 20 Cr. 330 (AJN) x ALISON J. NATHAN, United States District Judge: WHEREAS the Government intends to produce to GHISLAINE MAXWELL, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prematurely disclosed, the Government's ongoing investigation; (iii) would risk prejudicial pretrial publicity if publicly disseminated, and (iv) is not authorized to be disclosed to the public or disclosed beyond that which is necessary for the defense of this action, and other materials pursuant to Federal Rule of Criminal Procedure 16 ("Rule 16") and pursuant to any other disclosure obligations (collectively, the "Discovery"), which cont

Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 P

Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 P UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA GHISLAINE MAXWELL, Defendant. x 1nf19 WO USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED:7/30/2020 PROTECTIVE ORDER 20 Cr. 330 (AJN) x ALISON J. NATHAN, United States District Judge: WHEREAS the Government intends to produce to GHISLAINE MAXWELL, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prematurely disclosed, the Government's ongoing investigation; (iii) would risk prejudicial pretrial publicity if publicly disseminated, and (iv) is not authorized to be disclosed to the public or disclosed beyond that which is necessary for the defense of this action, and other materials pursuant to Federal Rule of Criminal Procedure 16 ("Rule 16") and pursuant to any other disclosure obligations (collectively, the "Discovery"), which cont

EFTA00009664

Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 P

Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 P UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA GHISLAINE MAXWELL, Defendant. x 1nf19 WO USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED:7/30/2020 PROTECTIVE ORDER 20 Cr. 330 (AJN) x ALISON J. NATHAN, United States District Judge: WHEREAS the Government intends to produce to GHISLAINE MAXWELL, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prematurely disclosed, the Government's ongoing investigation; (iii) would risk prejudicial pretrial publicity if publicly disseminated, and (iv) is not authorized to be disclosed to the public or disclosed beyond that which is necessary for the defense of this action, and other materials pursuant to Federal Rule of Criminal Procedure 16 ("Rule 16") and pursuant to any other disclosure obligations (collectively, the "Discovery"), which cont