EFTA00009658.pdf

Case 1:19-cr-00490-RMB Document 38 Filed 07/25/19 Page 1 of 5 
Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 1 of 9 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA 
JEFFREY EPSTEIN, 
Defendant. 
x 
USDC SDNY 
DOCUMENT 
ELECTRONICALLY FILED 
DOT!{: 
DATE FILED:S
4
PROTECTIVE ORDER 
19 Cr. 490 (RMB) 
 
 x 
RICHARD M. BERMAN, United States District Judge: 
WHEREAS the Government intends to produce to JEFFREY 
EPSTEIN, 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 of uncharged individuals; (iii) 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; 
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e) 
May be shown to, but not disseminated to or 
provided copies of to, prospective witnesses and their counsel 
(collectively, "Potential Witnesses"), to the extent deemed 
necessary by defense counsel, for trial preparation. 
2. 
To the extent the Discovery is disclosed to 
Defense Staff, Defense Experts/Advisors, Other Authorized 
Persons, or Potential Witnesses, Defense Counsel shall instruct 
such individual(s) of the terms of this Order and that such 
individual(s) are bound by this order. To the extent that 
Discovery is disseminated to Defense Staff, Defense 
Experts/Advisors, or Other Authorized Persons, Defense counsel 
shall encrypt and/or password protect the Discovery. The 
provisions of this paragraph do not apply to communications 
exclusively between and among Defense Counsel. 
3. 
The Government, the Defendant, Defense Counsel, 
Defense Staff, Defense Experts/Advisors, Potential Witnesses, 
and Other Authorized Persons are prohibited from posting or 
causing to be posted any of the Discovery or information 
contained in the Discovery on the Internet, including any social 
media website. 
4. 
The Government (other than in the discharge of 
their professional obligations in this matter), Defense Counsel, 
Defense Staff, Defense Experts/Advisors, Potential Witnesses, 
and Other Authorized Persons are precluded from publicly 
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other identifying designation, are deemed "Confidential 
Information." 
7. 
Confidential Information may contain personal 
identification information of specific individuals who are not 
parties to this action, and other confidential information; as 
well as information that identifies, or could lead to the 
identification of, witnesses in this matter. The Government's 
designation of material as Confidential Information will be 
controlling absent contrary order of the Court. 
8. 
Confidential Information disclosed to the 
defendant, or Defense Counsel, respectively, during the course 
of proceedings in this action: 
a) 
Shall be used by the defendant or his 
counsel only for purposes of the defense of this action; 
b) 
Shall be maintained in a safe and secure 
manner solely by Defense Counsel; 
c) 
Shall be reviewed by the Defendant solely in 
the presence of Defense Counsel; 
d) 
shall not be possessed outside the presence 
of Defense Counsel, or maintained, by the Defendant; 
e) 
may be disclosed only by Defense Counsel and 
only to Designated Persons; 
f) 
May be shown to, but not disseminated to or 
provided copies of to, Potential witnesses, to the extent deemed 
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Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 7 of 9 
c) 
Shall not be possessed outside the presence 
of Defense Counsel, or maintained, by the Defendant; 
d) 
Shall be made available for inspection by 
Defense Counsel and the Defendant, under the protection of law 
enforcement officers or employees; and 
e) 
Shall not be copied or otherwise duplicated 
by Defense Counsel or the Defendant during such inspections. 
11. The Defendant and Defense Counsel shall provide a 
copy of this order to Designated Persons to whom they disclose 
Confidential Information or Highly Confidential Information. 
Prior to disclosure of such information to Designated Persons, 
any such Designated Person shall agree to be subject to the 
terms of this Order by signing a copy hereof and stating that 
they "Agree to be bound by the terms herein," and providing such 
copy to the defendant's counsel. However, the defendant and his 
or her respective counsel need not obtain signatures from any 
member of the defense team (i.e., attorneys, experts, 
consultants, paralegals, investigators, support personnel, and 
secretarial staff involved in the representation of the 
defendants in this case), all of whom are nonetheless bound by 
this Protective Order. 
12. Except for Discovery that has been made part of 
the record of this case, Defense Counsel shall return to the 
Government or securely destroy or delete all Discovery, 
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13. The foregoing provisions shall remain in effect 
unless and until either (a) the Government and Defense Counsel 
mutually agree otherwise, or (b) this Order is modified by 
further order of the Court. 
SO ORDERED: 
Dated: 
New York, New York 
ir, 2019 
AGREED AND CONSENTED TO: 
Dated: July 24, 2019 
New York, New York 
A 
mad' 
HONORABLE RICHARD M. BERMAN 
United States District Judge 
GEOFFREY S. BERMAN 
United States Attorney 
Southern District of New York 
By:  
/8/
Dated: 
MR,  as, 2019 
New York, New York 
Assistant United States Attorneys 
JEFFREY EPSTEIN 
By: Z
ia_ 
Martin Weinberg, Esq. 
Reid Weingarten, Esq. 
Counsel for Jeffrey Epstein 
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