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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
invoke the terms of this Order in writing to all Parties by designating Discovery Material "CONFIDENTIAL". Any such Protected Material produced by the non-party designated "CONFIDENTIAL" shall be subject to the restrictions contained in this Order and shall only be disclosed or used in a manner consistent w
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
invoke the terms of this Order in writing to all Parties by designating Discovery Material "CONFIDENTIAL". Any such Protected Material produced by the non-party designated "CONFIDENTIAL" shall be subject to the restrictions contained in this Order and shall only be disclosed or used in a manner consistent w
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
invoke the terms of this Order in writing to all Parties by designating Discovery Material "CONFIDENTIAL". Any such Protected Material produced by the non-party designated "CONFIDENTIAL" shall be subject to the restrictions contained in this Order and shall only be disclosed or used in a manner consistent w
Entities connected to both Challenging Designations Of Protected Material and the non-party

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