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Case 1:20-cr-00330-AJN Document 33-1 Filed 07/28/20 Page 1 of 12
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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UNITED STATES OF AMERICA [PROPOSED]
PROTECTIVE ORDER
~v.-
20 Cr. 330 (AUN)
GHISLAINE MAXWELL,
Defendant.
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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;
DOJ-OGR-00001671