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the protective order in that case would prevent the Government from obtaining her testimony and using it in a subsequent criminal case against her. Second Circuit precedent expressly forecloses Maxwell's argument. "A Rule 26(c) protective order, no matter how broad its reach, provides no guarantee that compell
. No. 134-1 ¶ 13. A court may (as here) unseal documents covered by a civil protective order in the public interest. See Brown, 929 F.3d at 47; v. Marvell, 827 F. App'x 144, 145 (2d Cir. 2020); Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 126 (2d Cir. 2006). Civil litigants have neither a reasonab
uring two civil depositions conducted by Boies Schiller in a defamation action it filed against Maxwell on behalf of one of the firm's clients. v. Marvell, Case No. 15-cv-7433 (LAP) (S.D.N.Y). A Protective Order entered in that case prohibited the parties and their lawyers from sharing confidential di
Page: EFTA00011457 →es, and thirty-some depositions, including depositions of and Maxwell as well as several third parties. See Brown v. Maxwell, 929 F.3d 41, 46, 51 (2d Cir. 2019) (explaining that discovery was "hard-fought" and "extensive" and noting that the court file, which includes only some of the documents created
Page: EFTA00011459 →rs, and courts strictly enforce them. See, e.g., Stewart v. Hudson Hall LLC, 20 Civ. 885 (SLC), 2020 WL 7239676, at *2 (S.D.N.Y. Dec. 9, 2020) ("In the Second Circuit, there is a strict standard for modification of a protective order entered by a district court." (citation and quotation marks omitted)). This case
Page: EFTA00011467 →uring two civil depositions conducted by Boies Schiller in a defamation action it filed against Maxwell on behalf of one of the firm's clients. v. Marvell, Case No. 15-cv-7433 (LAP) (S.D.N.Y). A Protective Order entered in that case prohibited the parties and their lawyers from sharing confidential di
Page: EFTA00029082 →rders in civil litigation. Protective orders serve a "vital function" in civil litigation. Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291, 295 (2d Cir. 1979). They promote "the `secure the just, speedy, and inexpensive determination' of civil disputes, by encouraging full disclosure of all evidence.
Page: EFTA00029092 →rs, and courts strictly enforce them. See, e.g., Stewart v. Hudson Hall LLC, 20 Civ. 885 (SLC), 2020 WL 7239676, at *2 (S.D.N.Y. Dec. 9, 2020) ("In the Second Circuit, there is a strict standard for modification of a protective order entered by a district court." (citation and quotation marks omitted)). This case
Page: EFTA00029092 →uring two civil depositions conducted by Boies Schiller in a defamation action it filed against Maxwell on behalf of one of the firm's clients. v. Marvell, Case No. 15-cv-7433 (LAP) (S.D.N.Y). A Protective Order entered in that case prohibited the parties and their lawyers from sharing confidential di
Page: EFTA00029821 →rders in civil litigation. Protective orders serve a "vital function" in civil litigation. Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291, 295 (2d Cir. 1979). They promote "the `secure the just, speedy, and inexpensive determination' of civil disputes, by encouraging full disclosure of all evidence.
Page: EFTA00029831 →rs, and courts strictly enforce them. See, e.g., Stewart v. Hudson Hall LLC, 20 Civ. 885 (SLC), 2020 WL 7239676, at *2 (S.D.N.Y. Dec. 9, 2020) ("In the Second Circuit, there is a strict standard for modification of a protective order entered by a district court." (citation and quotation marks omitted)). This case
Page: EFTA00029831 →Entities connected to both Second Circuit and Marvell

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Julie K. Brown
PERSONthe Southern District
LOCATION
Prince Andrew
PERSON
Supreme Court
ORGANIZATIONJane Doe
PERSON
Michael Cohen
PERSON
Bradley Edwards
PERSON
Donald Trump
PERSONJeffrey Pagliuca
PERSON
David Boies
PERSON
Virginia Giuffre
PERSON
New York
LOCATION
Colorado
LOCATION
Stephen Hawking
PERSON
Denver
LOCATION
Alan Dershowitz
PERSONLeon Black
PERSON