EFTA00011445.pdf

Type: pdf
Source set: data-set-8
Extracted text

EXHIBIT A 
EFTA00011445


Case 1:15-cv-07433-RWS Document 62 Filed 03/18/16 Page 1 of 6 
Case 1:15-cv-07433-RWS Document 39-1 Filed 03/02/16 Page 2 of 7 
United States District Court 
Southern District Of New York.r 
X 
Plaintiff, 
v. 
Gbislaine Maxwell, 
Defendant. 
X 
15-cv-07433-RWS 
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 or information which 
will improperly annoy, embarrass, or oppress any party, witness, or person providing 
discovery in this case, 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. 
EFTA00011446


Case 1:15-cv-07433-RWS Document 62 Filed 03/18/16 Page 2 of 6 
Case 1:15-cv-07433-RWS Document 39-1 Filed 03/02/16 Page 3 of 7 
3. 
Information designated "CONFIDENTIAL" shall be information that is 
confidential and implicates common law and statutory privacy interests of (a) 
plainti  
 
and (b) defendant Ghislaine Maxwell. 
4. 
CONFIDENTIAL information shall not be disclosed or used for any purpose 
except the preparation and trial of this case. 
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; 
b. persons regularly employed or associated with the attorneys actively 
working on this cas…
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