DOJ-OGR-00002393.jpg

498 KB

Extraction Summary

3
People
2
Organizations
1
Locations
1
Events
1
Relationships
3
Quotes

Document Information

Type: Court document ([proposed] protective order)
File Size: 498 KB
Summary

This document is the first page of a '[Proposed] Protective Order' filed on March 4, 2016, in the civil case of Virginia L. Giuffre v. Ghislaine Maxwell in the Southern District of New York. The order outlines protocols for handling confidential information during discovery, specifically citing the need to protect sensitive personal information relating to victims of sexual abuse. It emphasizes that confidentiality designations should be used sparingly and must be withdrawn if the material no longer qualifies for protection.

People (3)

Name Role Context
Virginia L. Giuffre Plaintiff
Party initiating the lawsuit against Ghislaine Maxwell.
Ghislaine Maxwell Defendant
Party being sued by Virginia L. Giuffre.
RWS Judge (implied)
Initials in case number 15-cv-07433-RWS, referring to Judge Robert W. Sweet.

Organizations (2)

Name Type Context
United States District Court Southern District Of New York
Jurisdiction where the case is being heard.
DOJ-OGR
Department of Justice Office of Government Information Services (implied by footer stamp DOJ-OGR-00002393).

Timeline (1 events)

2016-03-04
Filing of Document 134-3 (Proposed Protective Order)
Southern District Of New York

Locations (1)

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

Relationships (1)

Virginia L. Giuffre Legal Adversaries Ghislaine Maxwell
Listed as Plaintiff and Defendant respectively in the case caption.

Key Quotes (3)

"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..."
Source
DOJ-OGR-00002393.jpg
Quote #1
"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."
Source
DOJ-OGR-00002393.jpg
Quote #2
"If it comes to a Designating Party’s attention that designated material does not qualify for protection at all... the Designating Party must promptly notify all other parties that it is withdrawing or changing the designation."
Source
DOJ-OGR-00002393.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (1,289 characters)

Case 1:15-cv-07433-RWS Document 134-3 Filed 03/04/16 Page 16 of 18
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.
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.
1
DOJ-OGR-00002393

Discussion 0

Sign in to join the discussion

No comments yet

Be the first to share your thoughts on this epstein document