Case 1:20-cr-00330-AJN Document 29 Filed 07/27/20 Page 1 of 4
COHEN & GRESSER LLP
Mark S. Cohen
+1 (212) 957-7600
[email protected]
Christian R. Everdell
+1 (212) 957-7600
[email protected]
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
DOJ-OGR-00001643