DOJ-OGR-00002384.jpg

508 KB

Extraction Summary

2
People
1
Organizations
1
Locations
1
Events
1
Relationships
1
Quotes

Document Information

Type: Legal document
File Size: 508 KB
Summary

This document is a proposed protective order filed on March 4, 2016, in the civil lawsuit between Plaintiff Virginia L. Giuffre and Defendant Ghislaine Maxwell in the Southern District of New York. The order aims to protect confidential information disclosed during discovery, such as details related to sexual abuse, trade secrets, or other sensitive material. It explicitly states that the order does not grant blanket protection and that any designation of material as confidential must be done sparingly and in good faith.

People (2)

Name Role Context
Virginia L. Giuffre Plaintiff
Listed as the Plaintiff in the case caption.
Ghislaine Maxwell Defendant
Listed as the Defendant in the case caption.

Organizations (1)

Name Type Context
United States District Court Southern District Of New York government agency
The court where the case is being heard.

Timeline (1 events)

2016-03-04
A [PROPOSED] PROTECTIVE ORDER was filed with the court in the case of Virginia L. Giuffre v. Ghislaine Maxwell.
United States District Court Southern District Of New York

Locations (1)

Location Context
The location of the United States District Court handling the case.

Relationships (1)

Virginia L. Giuffre is the Plaintiff and Ghislaine Maxwell is the Defendant in the legal case 1:15-cv-07433-RWS.

Key Quotes (1)

"The Parties acknowledge that this Order does not confer blanket protections on all disclosures during discovery."
Source
— The Parties (This quote is from the 'Purposes And Limitations' section, establishing a key constraint on the protective order.)
DOJ-OGR-00002384.jpg
Quote #1

Full Extracted Text

Complete text extracted from the document (1,426 characters)

Case 1:15-cv-07433-RWS Document 114-3 Filed 03/04/16 Page 2 of 23
United States District Court
Southern District Of New York
--------------------------------------
Virginia L. Giuffre,
Plaintiff,
v.
Ghislaine Maxwell,
Defendant.
--------------------------------------
15-cv-07433-RWS
[PROPOSED] PROTECTIVE ORDER
Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of confidential information, including sensitive personal information relating to a victim of sexual abuse, copyright or trade secrets, commercially sensitive information, or proprietary information, or information which will improperly annoy, embarrass, or oppress any party, witness, or person providing discovery in this case,
Purposes And Limitations
The Parties acknowledge that this Order does not confer blanket protections on all disclosures during discovery. Designations under this Order shall be made sparingly, with care, and shall not be made absent a good faith belief that the designated material satisfies the criteria set forth herein. If it comes to a Designating Party’s attention that designated material does not qualify for protection at all, or does not qualify for the level of protection initially asserted, the Designating Party must promptly notify all other parties that it is withdrawing or changing the designation.
DOJ-OGR-00002384

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