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CaGede22Q0eROOBI0o8UINe Dot Mer? 29-42 OF R88 078277 20g Fagef 4 2 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ote tt te tt tL UNITED STATES OF AMERICA [PROPOSED ] PROTECTIVE ORDER ye 20 Cr. 330 (AUN) GHISLAINE MAXWELL, Defendant. ~ oe LL LL 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; (i111) 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 contain sensitive, confidential, or personal identifying information; WHEREAS, the Government seeks to protect sensitive, confidential, or personal identifying information contained in the materials it produces consistent with Rule 16 or other disclosure obligations; - App.044 DOJ-OGR-00019503