This document is page 3 of a Protective Order filed on March 4, 2016, in the civil case between Virginia Roberts Giuffre and Ghislaine Maxwell. The document contains redline edits that significantly expand the scope of the order to protect the privacy of 'any non-party that was subject to sexual abuse' and explicitly allows confidential information to be used in 'investigations by law enforcement.' The text defines what constitutes confidential information and begins listing who may access it.
| Name | Role | Context |
|---|---|---|
| Virginia Roberts Giuffre | Plaintiff |
Named as a party whose privacy protections are covered by the order.
|
| Ghislaine Maxwell | Defendant |
Named as a party whose privacy protections are covered by the order.
|
| Name | Type | Context |
|---|---|---|
| Federal Court |
Implied by 'Federal Rules of Civil Procedure' and case styling.
|
|
| Law Enforcement |
Explicitly added as an entity permitted to receive confidential information in paragraph 4.
|
|
| DOJ |
Department of Justice, indicated in the Bates stamp (DOJ-OGR).
|
"Information designated 'CONFIDENTIAL' shall be information that is confidential and... is covered by common law and statutory privacy protections of... (c) any non-party that was subject to sexual abuse."Source
"CONFIDENTIAL information shall not be disclosed... except the preparation and trial of this case and any related matter, including but not limited to, investigations by law enforcement."Source
Complete text extracted from the document (1,551 characters)
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