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with their legibility) the following or other appropriate notice: "CONFIDENTIAL." Discovery material designated CONFIDENTIAL shall be identified by Bates number. To the extent practical, the respective legend shall be placed near the Bates number. 8. Designation of a document as CONFIDENTIAL INFORMA
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
with their legibility) the following or other appropriate notice: "CONFIDENTIAL." Discovery material designated CONFIDENTIAL shall be identified by Bates number. To the extent practical, the respective legend shall be placed near the Bates number. 8. Designation of a document as CONFIDENTIAL INFORMA
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
with their legibility) the following or other appropriate notice: "CONFIDENTIAL" Discovery material designated CONFIDENTIAL shall be identified by Bates number. To the extent practical, the respective legend shall be placed near the Bates number. Designation of a document as CONFIDENTIAL INFORMATION
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
with their legibility) the following or other appropriate notice: "CONFIDENTIAL." Discovery material designated CONFIDENTIAL shall be identified by Bates number. To the extent practical, the respective legend shall be placed near the Bates number. 8. Designation of a document as CONFIDENTIAL INFORMA
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
Entities connected to both Bates and the Protected Material

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