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Correspondence · July 9, 2020

Counsel email transmitting draft protective order for discovery, July 2020

Email from counsel transmitting a draft protective order for discovery, noting revisions to an attached version and anticipating pushback from opposing parties.Machine-written summary

Date: Thu, 09 Jul 2020 18:52:51 +0000

Attachments: 2020-07-03,_GM,_protective_order_fordiscoveryJAJN).docx

Paragraph three in what I sent is superfluous — it’s removed in the attached, but if you’re already reviewing, no problem, just ignore that para.

From: Sent: Thursday, July 09, 2020 14:47 To:

Subject: cyan protective order

Team, apologies again for the delay on this (among other things — and you’ll be entertained by this —

*!!), but draft is attached. It is as strong as I could think to make it, but very happy to take additional thoughts or suggestions, and I anticipate we’ll likely get some pushback but we can see what they say. Thoughts / comments / edits? Thanks.

Counsel email transmitting draft protective order for discovery, July 2020

Emails and letters

Email from counsel transmitting a draft protective order for discovery, noting revisions to an attached version and anticipating pushback from opposing parties.

DOJ Epstein Files, Data Set 8 · July 9, 2020

Date: Thu, 09 Jul 2020 18:52:51 +0000 Attachments: 2020-07-03, GM, protective order fordiscoveryJAJN).docx Paragraph three in what I sent is superfluous — it's removed in the attached, but if you're already reviewing, no problem, just ignore that para. From: Sent: Thursday, July 09, 2020 14:47 To: Subject: cyan protective order Team, apologies again for the delay on this (among other things — and you'll be entertained by this — !!), but draft is attached. It is as strong as I could think to make it, but very happy to take additional thoughts or suggestions, and I anticipate we'll likely get so…