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he Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. 11. Challenging Designations Of Protected Material (a) A Party shall not be obligated to challenge the propriety of any designation o
otential witnesses; h. any person (1) who authored or received the particular Protected Material; (2) who has or had at any point in time access to the Protected Material outside of the context of this action; or (3) for which there is a good faith basis to conclude that the individual has earlier received or seen su
he Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. 11. Challenging Designations Of Protected Material (a) A Party shall not be obligated to challenge the propriety of any designation o
otential witnesses; h. any person (1) who authored or received the particular Protected Material; (2) who has or had at any point in time access to the Protected Material outside of the context of this action; or (3) for which there is a good faith basis to conclude that the individual has earlier received or seen su
he Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. A party may object to tha thsignation of particular CONFIDENTIAL' I.N.F4RMA-TION-br giving-weiten-neke-te-the-pany-designating-the-d.i
tial witnesses; and h. any person (1) who authored or received the particular Protected Material: (2) who has or had at any point in time access to the Protected Material outside of the context of this action: or (3) for which there is a good faith basis to conclude that the individual has earlier received or seen su
Entities connected to both the Southern District and the Protected Material

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
New York
LOCATION
David Boies
PERSONSigrid McCawley
PERSONLaura Menninger
PERSONBates
PERSONHaddon
PERSON
Foreman
PERSONSCHILLER & FLEXNER LLP
ORGANIZATIONChallenging Designations Of Protected Material
ORGANIZATIONthe non-party
ORGANIZATIONthe Receiving Party
ORGANIZATIONCONFIDENTIALshall
ORGANIZATIONthe Producing Party
ORGANIZATION