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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
a failure to do so shall not preclude a subsequent challenge thereto. Moreover, failure to challenge the designation of any Discovery Material as CONFIDENTIALshall not in any way constitute an admission that such material contains any competitively sensitive information, trade secret information, or other prot
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
a failure to do so shall not preclude a subsequent challenge thereto. Moreover, failure to challenge the designation of any Discovery Material as CONFIDENTIALshall not in any way constitute an admission that such material contains any competitively sensitive information, trade secret information, or other prot
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
a failure to do so shall not preclude a subsequent challenge thereto. Moreover, failure to challenge the designation of any Discovery Material as CONFIDENTIALshall not in any way constitute an admission that such material contains any competitively sensitive information, trade secret information, or other prot
Entities connected to both Challenging Designations Of Protected Material and CONFIDENTIALshall

Ghislaine Maxwell
PERSONSigrid McCawley
PERSONthe Protected Material
ORGANIZATIONBates
PERSON
David Boies
PERSONLaura Menninger
PERSONthe non-party
ORGANIZATION
Foreman
PERSONHaddon
PERSONthe Receiving Party
ORGANIZATIONSCHILLER & FLEXNER LLP
ORGANIZATIONthe Producing Party
ORGANIZATIONthe Southern District
LOCATION