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United States District Court
Southern District Of New York

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[REDACTED]
Plaintiff,

v.

Ghislaine Maxwell,

Defendant.

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15-cv-07433-RWS

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 or information which
will improperly annoy, embarrass, or oppress any party, witness, or person providing
discovery in this case, IT IS ORDERED:

1. This Protective Order shall apply to all documents, materials, and information,
including without limitation, documents produced, answers to interrogatories,
responses to requests for admission, deposition testimony, and other
information disclosed pursuant to the disclosure or discovery duties created by
the Federal Rules of Civil Procedure.

2. As used in this Protective Order, “document” is defined as provided in
FED.R.CIV.P. 34(a). A draft or non-identical copy is a separate document
within the meaning of this term.

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3. Information designated “CONFIDENTIAL” shall be information that is
confidential and implicates common law and statutory privacy interests of (a)
plaintiff [REDACTED] and (b) defendant Ghislaine Maxwell.

4. CONFIDENTIAL information shall not be disclosed or used for any purpose
except the preparation and trial of this case.

5. CONFIDENTIAL documents, materials, and/or information (collectively
“CONFIDENTIAL INFORMATION”) shall not, without the consent of the
party producing it or further Order of the Court, be disclosed except that such
information may be disclosed to:

a. attorneys actively working on this case;

b. persons regularly employed or associated with the attorneys actively
working on this case whose assistance is required by said attorneys in the
preparation for trial, at trial, or at other proceedings in this case;

c. the parties;

d. expert witnesses and consultants retained in connection with this
proceeding, to the extent such disclosure is necessary for preparation, trial
or other proceedings in this case;

e. the Court and its employees (“Court Personnel”) in this case;

f. stenographic reporters who are engaged in proceedings necessarily incident
to the conduct of this action;

g. deponents, witnesses, or potential witnesses; and

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h. other persons by written agreement of the parties.

6. Prior to disclosing any CONFIDENTIAL INFORMATION to any person
listed above (other than counsel, persons employed by counsel, Court
Personnel and stenographic reporters), counsel shall provide such person with
a copy of this Protective Order and obtain from such person a written
acknowledgment stating that he or she has read this Protective Order and
agrees to be bound by its provisions. All such acknowledgments shall be
retained by counsel and shall be subject to in camera review by the Court if
good cause for review is demonstrated by opposing counsel.

7. Documents are designated as CONFIDENTIAL by placing or affixing on them
(in a manner that will not interfere with their legibility) the following or other
appropriate notice: “CONFIDENTIAL.” Discovery material designated
CONFIDENTIAL shall be identified by Bates number. To the extent practical,
the respective legend shall be placed near the Bates number.

8. Designation of a document as CONFIDENTIAL INFORMATION shall
constitute a representation that such document has been reviewed by an
attorney for the designating party, that there is a valid and good faith basis for
such designation, made at the time of disclosure or production to the receiving
party, and that disclosure of such information to persons other than those
permitted access to such material would cause a privacy harm to the
designating party.

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9. Whenever a deposition involves the disclosure of CONFIDENTIAL
INFORMATION, the deposition or portions thereof shall be designated as
CONFIDENTIAL and shall be subject to the provisions of this Protective
Order. Such designation shall be made on the record during the deposition
whenever possible, but a party may designate portions of depositions as
CONFIDENTIAL after transcription, provided written notice of the
designation is promptly given to all counsel of record within thirty (30) days
after notice by the court reporter of the completion of the transcript, and until
the expiration of such thirty (30) days after notice by the court reporter of the
completion of the transcript, no party or counsel for any such party may share
the contents of the deposition outside the limitations of this Protective Order.

10. Whenever a party seeks to file any document or material containing
CONFIDENTIAL INFORMATION with the Court in this matter, it shall be
accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic
Case Filing Rules & Instructions for the Southern District of New York.

11. A party may object to the designation of particular CONFIDENTIAL
INFORMATION by giving written notice to the party designating the disputed
information. The written notice shall identify the information to which the
objection is made. If the parties cannot resolve the objection within ten (10)
business days after the time the notice is received, it shall be the obligation of
the party designating the information as CONFIDENTIAL to file an

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appropriate motion requesting that the Court determine whether the disputed
information should be subject to the terms of this Protective Order. If such a
motion is timely filed, the disputed information shall be treated as
CONFIDENTIAL under the terms of this Protective Order until the Court rules
on the motion. If the designating party fails to file such a motion within the
prescribed time, the disputed information shall lose its designation as
CONFIDENTIAL and shall not thereafter be treated as CONFIDENTIAL in
accordance with this Protective Order. In connection with a motion filed under
this provision, the party designating the information as CONFIDENTIAL shall
bear the burden of establishing that good cause exists for the disputed
information to be treated as CONFIDENTIAL.

12. At the conclusion of this case, unless other arrangements are agreed upon, each
document and all copies thereof which have been designated as
CONFIDENTIAL shall be returned to the party that designated it
CONFIDENTIAL, or the parties may elect to destroy CONFIDENTIAL
documents. Where the parties agree to destroy CONFIDENTIAL documents,
the destroying party shall provide all parties with an affidavit confirming the
destruction.

13. This Protective Order shall have no force and effect on the use of any
CONFIDENTIAL INFORMATION at trial in this matter.

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14. This Protective Order may be modified by the Court at any time for good cause
shown following notice to all parties and an opportunity for them to be heard.

BY THE COURT

[Signature]
UNITED STATES DISTRICT JUDGE
3-17-16

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