Document 136-3

Case 1:20-cr-00330-AJN Document 136-3 Filed 02/04/21 Page 1 of 1 EXHIBIT C FILED UNDER SEAL DOJ-OGR-00002439 --- PAGE BREAK --- Case 1:19-cv-09338-AWS Document 136-3 Filed 03/04/26 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. DOJ-OGR-00002449 --- PAGE BREAK --- Case 1:19-cv-09233-AJN Document 136-3 Filed 03/04/21 Page 8 of 28 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. 3. Information designated "CONFIDENTIAL" shall be information that is confidential and implicates is covered by common law and statutory privacy interests-protections of (a) plaintiff Virginia Roberts Giuffre and (b) defendant Ghislaine Maxwell or (c) any non-party that was subject to sexual abuse. 4. CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case and any related matter, including but not limited to, investigations by law enforcement. 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;