DOJ-OGR-00002389(1).jpg

648 KB

Extraction Summary

1
People
2
Organizations
0
Locations
2
Events
1
Relationships
3
Quotes

Document Information

Type: Court filing (draft/redlined protective order)
File Size: 648 KB
Summary

This is page 12 of a legal filing (Case 1:15-cv-07433-RWS, Giuffre v. Maxwell) filed on March 4, 2016. It outlines the procedures for challenging 'Confidential' or 'Highly Confidential' designations of discovery material. It specifies that failing to challenge a designation immediately does not waive the right to do so later, and outlines a process requiring written notice and potential court hearings to resolve disputes over these designations.

People (1)

Name Role Context
RWS Judge
Judge Robert W. Sweet (implied by case number in header)

Organizations (2)

Name Type Context
Department of Justice (DOJ)
Indicated by footer stamp DOJ-OGR-00002389
The Court
Venue for hearings regarding designation disputes

Timeline (2 events)

2016-03-04
Document Filed
Court
Hypothetical
Hearing before the Court
Court
Receiving Party Producing Party Designating Party

Relationships (1)

Producing Party Legal Opponents/Counterparties Receiving Party
Protocol for objecting to material designations between parties.

Key Quotes (3)

"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."
Source
DOJ-OGR-00002389(1).jpg
Quote #1
"failure to challenge the designation of any Discovery Material... shall not in any way constitute an admission that such material contains any competitively sensitive information"
Source
DOJ-OGR-00002389(1).jpg
Quote #2
"The Parties will use their best efforts to resolve such objections among themselves."
Source
DOJ-OGR-00002389(1).jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (2,020 characters)

Case 1:15-cv-07433-RWS Document 134-2 Filed 03/04/16 Page 12 of 23
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.
11. Challenging Designations Of Protected Material
(a) A Party shall not be obligated to challenge the propriety of any designation of Discovery Material under this Order at the time the designation is made, and a failure to do so shall not preclude a subsequent challenge thereto. Moreover, failure to challenge the designation of any Discovery Material as CONFIDENTIAL or HIGHLY CONFIDENTIAL—ATTORNEYS’ EYES ONLY shall not in any way constitute an admission that such material contains any competitively sensitive information, trade secret information, or other protectable material.
12. (b) In the event that counsel for the Party receiving CONFIDENTIAL Material objects to the CONFIDENTIAL or HIGHLY CONFIDENTIAL—ATTORNEYS’ EYES ONLY designation of any or all such items, said counsel shall provide the Producing Party and, if different, the Designating Party written notice of, and the basis for, such objections. The Parties will use their best efforts to resolve such objections among themselves. Should the Receiving Party, the Producing Party and, if different, the Designating Party be unable to resolve the objections, the Receiving Party may seek a hearing before this Court with respect to the propriety of the designation. The
[Right Margin Formatting Notes]:
Formatted: Font: 12 pt, Bold, Underline, Font color: Black
Formatted: Font: 12 pt, Font color: Black
Formatted: Normal, No bullets or numbering
Formatted: Font: 12 pt
Formatted: Indent: Left: 0.5", Hanging: 0.5", No bullets or numbering, Tab stops: 1",
Formatted: Font: 12 pt
Formatted: Font: 12 pt
Formatted: Font: 12 pt
Formatted: Font: 12 pt
Formatted: Font: 12 pt, Font color: Black
Formatted: Font: 12 pt, Font color: Black
DOJ-OGR-00002389

Discussion 0

Sign in to join the discussion

No comments yet

Be the first to share your thoughts on this epstein document