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Document 121-3

AI Analysis

Summary: The document is a proposed protective order in the case of Virginia L. Giuffre v. Ghislaine Maxwell, outlining the guidelines for designating and handling confidential and sensitive information during discovery. The order aims to protect victims of sexual abuse and proprietary information while allowing for necessary disclosures. It requires designations to be made sparingly and with care.
Significance: This proposed protective order is significant because it outlines the procedures for handling sensitive and confidential information in the case, including information related to victims of sexual abuse and proprietary information.
Key Topics: Confidentiality and protection of sensitive information Discovery and dissemination of personal and proprietary information Guidelines for designation and handling of protected materials
Key People:
  • Virginia L. Giuffre - Plaintiff
  • Ghislaine Maxwell - Defendant
Document Type
Court Filing
Date
02/04/26
Pages
1
Folder
IMAGES001

Full Text

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