This document is a declaration by Sigrid S. McCawley, a partner at Boies, Schiller & Flexner LLP, in support of the plaintiff's response to Ghislaine Maxwell's motion for a protective order. It includes references to various exhibits such as deposition notices and email correspondence. The document also contains a proposed protective order to safeguard confidential information in the case, including sensitive personal information, trade secrets, and proprietary information. The order outlines the handling of confidential information and the process for challenging designations of such material.
documents/EFTA00095531.pdf
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