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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
ompanied 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 of Discovery Material under this Order at the time the designation
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
ompanied 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 of Discovery Material under this Order at the time the designation
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
ompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. II. Challenging Designations Of Protected Material (a) A Party shall not be obligated to challenge the propriety of any designation of discovery material under this Order at the time the designation
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
ompanied 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 of Discovery Material under this Order at the time the designation
Entities connected to both the Protected Material and Challenging Designations Of Protected Material

David Boies
PERSONLaura Menninger
PERSONSigrid McCawley
PERSONBates
PERSON
Ghislaine Maxwell
PERSONSCHILLER & FLEXNER LLP
ORGANIZATIONCONFIDENTIALshall
ORGANIZATIONthe Producing Party
ORGANIZATIONthe non-party
ORGANIZATION
Foreman
PERSONthe Southern District
LOCATIONHaddon
PERSONthe Receiving Party
ORGANIZATION