DOJ-OGR-00002384(1).jpg

508 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: 508 KB
Summary

This is page 2 of a Proposed Protective Order filed on March 4, 2016, in the civil case Giuffre v. Maxwell (15-cv-07433-RWS) in the SDNY. The document outlines the limitations of confidentiality protections during discovery, specifically noting protections for sensitive personal information regarding sexual abuse victims. It includes visible track-changes/strikethroughs removing language about 'annoying' or 'embarrassing' parties, and contains formatting metadata on the right sidebar.

People (3)

Name Role Context
Virginia L. Giuffre Plaintiff
Named plaintiff in the civil lawsuit.
Ghislaine Maxwell Defendant
Named defendant in the civil lawsuit.
RWS Judge
Initials in case number indicating 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
Implied by the footer 'DOJ-OGR' (Department of Justice).

Timeline (1 events)

2016-03-04
Filing of Document 124-3 (Proposed Protective Order)
United States District Court Southern District Of New York

Locations (1)

Location Context
Location of the court.

Relationships (1)

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

Key Quotes (3)

"including sensitive personal information relating to a victim of sexual abuse"
Source
DOJ-OGR-00002384(1).jpg
Quote #1
"The Parties acknowledge that this Order does not confer blanket protections on all disclosures during discovery."
Source
DOJ-OGR-00002384(1).jpg
Quote #2
"Designations under this Order shall be made sparingly, with care"
Source
DOJ-OGR-00002384(1).jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (1,622 characters)

Case 1:15-cv-07433-RWS Document 124-3 Filed 03/04/16 Page 2 of 28
United States District Court
Southern District Of New York
---------------------------
Virginia L. Giuffre,
Plaintiff,
v. 15-cv-07433-RWS
Ghislaine Maxwell,
Defendant.
---------------------------
[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.
[Formatted Comments Sidebar]
Formatted: List Paragraph, Indent: First line: 0", Space Before: 0 pt, Line spacing: Double
Formatted: Font: 12 pt, Font color: Black
Formatted: Indent: First line: 0.5", Space Before: 0 pt, Line spacing: Double
DOJ-OGR-00002384

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