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Cased ADAH SB0s AT en dc WHE 302 CF iRABS2A80/Pageewelleo2 USDC SDNY DOCUMENT ELECTRONICALLY FILED UNITED STATES DISTRICT COURT hit ieee 3.5, 7 aa SOUTHERN DISTRICT OF NEW YORK DATE FILED://30/2020 _ United States of America, _y_ 20-CR-330 (AJN) Ghislaine Maxwell, MEMORANDUM Defendant. 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 the following reasons, the Court adopts the Government’s proposed protective order. Under Federal Rule of Criminal Procedure 16(d)(1), “[a]t any time the court may, for good cause, deny, restrict, or defer discovery or inspection, or grant other appropriate relief.” The good cause standard “requires courts to balance several interests, including whether dissemination of the discovery materials inflicts hazard to others . . . whether the imposition of the protective order would prejudice the defendant,” and “the public’s interest in the information.” United States v. Smith, 985 F. Supp. 2d 506, 522 (S.D.N.Y. 2013). The party seeking to restrict disclosure bears the burden of showing good cause. Cf Gambale v. Deutsche Bank AG, 377 F.3d 133, 142 (2d Cir. 2004). App.087 DOJ-OGR-00019546