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Casecl ZDAPCOOSB0s ATE (ido WB Ert/ 202 FiRAB6 ZR /PagPiigefil ab4 COHEN & GRESSER LLP Mark S. Cohen +1 (212) 957-7600 mcohen@cohengtesset.com Christian R. Everdell +1 (212) 957-7600 cevetdell@cohengresset.com July 27, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse AO Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: On behalf of our client, Ghislaine Maxwell, we respectfully request that the Court enter a protective order in the form attached hereto as Exhibit A. The government has indicated that it requires the entry of a protective order before producing any discovery material to Ms. Maxwell. On July 9, 2020, the government provided defense counsel with an initial draft of a proposed protective order. Since that time, the parties have conferred several times on conference calls and by email, and have been able to reach agreement on almost all of the provisions of the proposed protective order. Two key disputes remain, however, which require the Court’s guidance. First, the defense believes that potential government witnesses and their counsel should be subject to the same restrictions as the defense concerning appropriate use of the discovery materials—namely, if these individuals are given access to discovery materials during trial preparation, they may not use those materials for any purpose other than preparing for trial in the criminal case, and may not post those materials on the Internet. Second, the defense believes it should not be restricted from publicly disclosing or disseminating the identity of any alleged victims or potential witnesses referenced in the discovery materials who have already identified themselves by speaking on the public record. As set forth below, we believe that the proposed protective order contains appropriate restrictions that are no broader than necessary to protect the privacy interests of individuals App.039 DOJ-OGR- 00019498