Document 1:19-cr-00490-RMB Document 38

Case 1:19-cr-00490-RMB Document 38 Filed 07/25/19 Page 2 of 9 Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 2 of 9 WHEREAS the defendant, through his counsel, consents to the entry of this Order; IT HEREBY IS ORDERED: 1. The Discovery disclosed to the defendant ("Defendant") and/or to the defendant's attorneys ("Defense Counsel") during the course of proceedings in this action: a) Shall be used by the defendant or his counsel solely for purposes of the defense of this action; b) Shall not be copied or otherwise recorded or transmitted by the defendant; c) Shall not be disclosed or distributed in any form by the defendant or his counsel except as set forth in paragraph 2(d) below; d) May be disclosed only by Defense Counsel and only to the following persons ("Designated Persons"): i. investigative, secretarial, clerical, or paralegal personnel employed full-time or part-time by the defendant's counsel ("Defense Staff"); ii. any expert, advisor, or any other individual retained or employed by the Defendant and Defense Counsel for the purpose of assisting in the defense of this case ("Defense Experts/Advisors"); iii. such other persons as hereafter may be authorized by Order of the Court ("Other Authorized Persons"); 2 DOJ-OGR-00000596 --- PAGE BREAK --- Case 1:19-cr-00490-RMB Document 38 Filed 07/25/19 Page 4 of 9 Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 4 of 9 disclosing or disseminating the identity of any victims or witnesses referenced in the Discovery. This Order does not prohibit Defense Counsel from publicly referencing individuals who have spoken on the public record in litigation - criminal or otherwise - relating to Jeffrey Epstein. 5. The Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Witnesses, and Other Authorized Persons are prohibited from filing publicly as an attachment to a filing or excerpted within a filing any of the Discovery or information contained in the Discovery, unless authorized by the Government in writing or by Order of the Court. Any filings that incorporate the Discovery by attachment, contain any excerpts of Discovery, or incorporate Discovery by reference must be filed under seal. Nothing in this Order precludes Defense Counsel from using the Discovery in judicial proceedings in this case. 6. Copies of Discovery or other materials produced by the Government in this action bearing "confidential" stamps or otherwise designated as "confidential" and/or electronic Discovery materials designated as "confidential" by the Government, including such materials marked as "confidential" either on the documents or materials themselves, or designated as "confidential" in a cover letter, index, folder title, or 4 DOJ-OGR-00000598