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Case 22-1426, Document “Tato | 3475900, Page16 of 208 | A-12_ 2/22/23, 1:25 PM SDNY CM/ECF NextGen Version 1.6 have no relevance to the charges in this case. These individuals still maintain a significant privacy interest that must be safeguarded. The exception the Defense seeks is too broad and risks undermining the protections of the privacy of witnesses and alleged victims that is required by law. In contrast, the Government's proffered language would allow Ms. Maxwell to publicly reference individuals who have spoken by name on the record in this case. It also allows the Defense to "referenc[e] the identities of individuals they believe may be relevant... to Potential Defense Witnesses and their counsel during the course of the investigation and preparation of the defense case at trial." Dkt. No. 33-1, 5. This proposal adequately balances the interests at stake. And as the Government's letter notes, see Dkt. No. 33 at 4, to the extent that the Defense needs an exception to the protective order for a specific investigative purpose, they can make applications to the Court on a case-by-case basis. Second, restrictions on the ability of potential witnesses and their counsel to use discovery materials for purposes other than preparing for trial in this case are unwarranted. The request appears unprecedented despite the fact that there have been many high-profile 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 https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.pl?211087015221896-L_1_0-1 12/113 DOJ-OGR- 00020634