EpsteinProject.org

Court records

013-01_7

Format
pdf
Set
Court Records
Text
Searchable

View at the original source

Text as released

Machine-read from the scan. Names, dates and numbers can be misread — check anything you rely on against the original page.

     Case 1:19-cr-00830-AT    Document 13-1   Filed 12/16/19   Page 1 of 5




UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
- - - - - - - - - - - - - - -          x
UNITED STATES OF AMERICA               :      PROTECTIVE ORDER

             -v.-                      :      19 Cr. 830 (AT)

TOVA NOEL and                          :
MICHAEL THOMAS,
                                       :
                    Defendants.
                                       :
- - - - - - - - - - - - - - -          x

     On the motion of the United States of America, by the United

States Attorney for the Southern District of New York, Geoffrey S.

Berman, by Assistant United States Attorneys Rebekah Donaleski,

Nicolas Roos, and Jessica Lonergan; and with the consent of TOVA

NOEL and MICHAEL THOMAS, the defendants, by and through their

respective counsel of record:

     WHEREAS, TOVA NOEL and MICHAEL THOMAS, the defendants, have

certain   rights    under    the   United   States   Constitution,     federal

statutes, and the Federal Rules of Criminal Procedure, to pretrial

discovery;

     WHEREAS, the Government recognizes its obligation to provide

such discovery materials to the defendants, consistent with the

need to protect the confidentiality of ongoing investigations and

the confidentiality interests of others;

     WHEREAS, the discovery that the Government intends to provide

to the defendants contain materials that, if disseminated to third
     Case 1:19-cr-00830-AT   Document 13-1   Filed 12/16/19   Page 2 of 5



parties, could, among other things, impede ongoing investigations

and implicate the privacy and confidentiality interests of third

parties;

     WHEREAS, the Government has demonstrated good cause for the

relief set forth herein;

     WHEREAS, TOVA NOEL and MICHAEL THOMAS, the defendants, by and

through their respective counsel of record, consent to the entry

of this Order;

     NOW, THEREFORE, IT IS HEREBY ORDERED, pursuant to F

[…]

Open in the archive