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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
written notice of, and the basis for, such objections. The Parties will use their best efforts to resolve such objections among themselves. Should the Receiving Party, the Producing Party and, if different, the Designating Party be unable to resolve the EFTA00084362 02/26/2016 IA iciP§Ax1:15-cv-07433-LAP Docume
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
written notice of, and the basis for, such objections. The Parties will use their best efforts to resolve such objections among themselves. Should the Receiving Party, the Producing Party and, if different, the Designating Party be unable to resolve the EFTA00094800 02/26/2016 IA iciP§Ax1:15-cv-07433-LAP Docume
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
written notice of, and the basis for, such objections. The Parties will use their best efforts to resolve such objections among themselves. Should the Receiving Party, the Producing Party and, if different, the Designating Party be unable to resolve the EFTA00075099 02/26/2016 14:clafig aBt24)/7213GelfArneracti
Entities connected to both the Protected Material and the Receiving Party

Ghislaine Maxwell
PERSONSigrid McCawley
PERSONBates
PERSONChallenging Designations Of Protected Material
ORGANIZATION
David Boies
PERSONLaura Menninger
PERSONthe non-party
ORGANIZATION
Foreman
PERSONHaddon
PERSONSCHILLER & FLEXNER LLP
ORGANIZATIONCONFIDENTIALshall
ORGANIZATIONthe Producing Party
ORGANIZATIONthe Southern District
LOCATION