Document 121-3

Case 1:19-cv-09333-AJN Document 121-3 Filed 02/04/26 Page 10 of 20 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. 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