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United States District Court 
Southern District Of New York 
Plaintiff, 
v. 
Ghislaine Maxwell, 
Defendant. 
15-cv-07433-RWS 
AGREED PROTECTIVE ORDER 
Upon a showing of good cause in support of the entry of a protective order to protect 
the discovery and dissemination of confidential information, including sensitive personal 
information relating to a victim of sexual abuse, copyright or trade secrets, commercially 
sensitive information, or proprietary information. 
I. 
Purposes And Limitations 
(a) 
The Parties acknowledge that this Order does not confer blanket protections on 
all disclosures during discovery. Designations under this Order shall be made sparingly, with 
care, and shall not be made absent a good faith belief that the designated material satisfies the 
criteria set forth herein. If it comes to a Designating Party's attention that designated material 
does not qualify for protection at all, or does not qualify for the level of protection initially 
asserted, the Designating Party must promptly notify all other parties that it is withdrawing or 
changing the designation. 
IT IS ORDERED: 
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1. 
This Protective Order shall apply to all documents, materials, and information, 
including without limitation, documents produced, answers to interrogatories, 
responses to requests for admission, deposition testimony, and other information 
disclosed pursuant to the disclosure or discovery duties created by the Federal 
Rules of Civil Procedure. 
2. 
As used in this Protective Order, "document" is defined as provided in 
FED.R.CIV.P. 34(a). A draft or non-identical copy is a separate document within 
the meaning of this term. 
3. 
Information designated "CONFIDENTIAL" shall be information that is 
confidential and is covered by common law and statutory privacy protections of 
(a) plaintiff 
hrid (b) defendant Ghislaine Maxwell or 
any non-party that was subject to sexual abuse. 
4. 
CONFIDENTIAL information shall not be disclosed or used for any purpose 
except the preparation and trial of this case and any related matter, including 
but not limited to, investigations by law enforcement. 
5. 
CONFIDENTIAL documents, materials, and/or information (collectively 
"CONFIDENTIAL INFORMATION") shall not, without the consent of the 
party producing it or further Order of the Court, be disclosed except that such 
information may be disclosed to: 
a. attorneys actively working on this case; 
b. persons regularly employed or associated with the attorneys actively 
working on this case whose assistance is required by said attorneys in the 
preparation for trial, at trial, or at other proceedings in this case; 
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c. the parties; 
d. expert witnesses and consultants retained in connection with this 
proceeding, to the extent such disclosure is necessary for preparation, trial 
or other proceedings in this case; 
e. the Court and its employees ("Court Personnel") in this case; 
f. stenographic reporters who are engaged in proceedings necessarily incident 
to the conduct of this action; 
g. deponents, witnesses, or potential 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 such Protected 
Material; and 
i. any other persons by written agreement of the parties or by Order of a Court 
of competent jurisdiction. 
6. 
Prior to disclosing any CONFIDENTIAL INFORMATION to any person 
listed above (other than counsel, persons employed by counsel, Court 
Personnel and stenographic reporters), counsel shall provide such person with 
a copy of this Protective Order and obtain from such person a written 
acknowledgment stating that he or she has read this Protective Order and 
agrees to be bound by its provisions. All such acknowledgments shall be 
retained by counsel and shall be subject to in camera review by the Court if 
good cause for review is demonstrated by opposing counsel. 
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7. 
Documents are designated as CONFIDENTIAL by placing or affixing on them 
(in a manner that will not interfere 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 INFORMATION shall 
constitute a representation that such document has been reviewed by an 
attorney for the designating party, that there is a valid and good faith basis for 
such designation, made at the time of disclosure or production to the receiving 
party, and that disclosure of such information to persons other than those 
permitted access to such material would cause a privacy harm to the 
designating party. 
9. 
Whenever a deposition involves the disclosure of CONFIDENTIAL 
INFORMATION, the deposition or portions thereof shall be designated as 
CONFIDENTIAL and shall be subject to the provisions of this Protective 
Order. Such designation shall be made on the record during the deposition 
whenever possible, but a party may designate portions of depositions as 
CONFIDENTIAL after transcription, provided written notice of the 
designation is promptly given to all counsel of record within thirty (30) days 
after notice by the court reporter of the completion of the transcript, and until 
the expiration of such thirty (30) days after notice by the court reporter of the 
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completion of the transcript, no party or counsel for any such party may share 
the contents of the deposition outside the limitations of this Protective Order. 
10. 
Whenever a party seeks to file any document or material containing 
CONFIDENTIAL INFORMATION with the Court in this matter, it shall be 
accompanied 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 is made, and 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 protectable material. 
(b) 
In the event that counsel for the Party receiving Protected Material objects 
to the CONFIDENTIAL designation of any or all such items, said counsel shall 
provide the Producing Party and, if different, the Designating Party written notice 
of, and the basis for, such objections. The Parties will use their best efforts to 
resolve such objections among themselves. Should the Receiving Party, the 
Producing Party and, if different, the Designating Party be unable to resolve the 
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objections, the Receiving Party may seek a hearing before this Court with respect 
to the propriety of the designation. The Designating Party will cooperate in 
obtaining a prompt hearing with respect thereto. 
Pending a resolution, the 
discovery material in question shall continue to be treated as Protected Material as 
provided hereunder. The burden of proving that Discovery Material is properly 
designated shall at all times remain with the Designating Party. 
12. 
At the conclusion of this case, unless other arrangements are agreed upon, each 
document and all copies thereof which have been designated as CONFIDENTIAL 
shall be returned to the party that designated it CONFIDENTIAL, or the parties 
may elect to destroy CONFIDENTIAL documents. Where the parties agree to 
destroy CONFIDENTIAL documents, the destroying party shall provide all parties 
with an affidavit confirming the destruction. 
13. 
With respect to any Discovery Material produced by such non-party, the non-party 
may 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 
with this Order. 
14. 
In the event that any Producing Party inadvertently produces Discovery Material 
eligible for designation as CONFIDENTIAL without such designation, the Parties 
agree that the Producing Party may retroactively apply the correct designation. If a 
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Producing Party makes a subsequent designation, the Receiving Party will treat the 
Protected Material according to the retroactive designation, including undertaking 
best efforts to retrieve all previously distributed copies from any recipients now 
ineligible to access the Protected Material. 
16. 
Limitations. Nothing in this Order shall restrict in any way the use or disclosure 
of Protected Material by a Receiving Party (a) that is or has become publicly 
known through no fault of the Receiving Party; (b) that is lawfully acquired by or 
known to the Receiving Party independent of the Producing Party; (c) that was 
previously produced, disclosed, and/or provided by the Producing Party to the 
Receiving Party or a non-party without an obligation of confidentiality and not by 
inadvertence or mistake; (d) with the consent of the Producing Party and, if 
different, the Designating Party; (e) pursuant to Order of the Court; or (f) for 
purposes of law enforcement.15. This Protective Order shall have no force and 
effect on the use of any CONFIDENTIAL INFORMATION at trial in this 
matter.This Protective Order may be modified by the Court at any time for good 
cause shown following notice to all parties and an opportunity for them to be 
heard. 
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BY THE COURT 
UNITED STATES DISTRICT JUDGE 
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New Jeffrey Epstein accuser says he molested her at 13, told her to 
wear children's underwear 
January18.2020 I 12:04am I Updated 
Jeffrey Epstein 
AP 
A woman claiming she was Jeffrey Epstein's "first-known victim" says she was sexually abused by the now-dead pedophile 
— who called himself her "Godfather" — when she was 13 years old. 
Jane Doe met Epstein and his friend, Ghislaine Maxwell, in the summer of 1994 at Michigan's interlochen Arts Camp, where 
she was In voice training, according to newly flied court papers suing Epstein's estate and Maxwell. 
The duo quickly took her under their wing, taking her to movies and on shopping trips in her home state of Florida and all 
the while grooming her for abuse, the Manhattan federal court suit says. 
Epstein "started to slowly display his pedophilic ways when shopping with Doe and Maxwell. Instead of letting Doe pick out 
clothes she wanted to wear, Epstein Insisted that she pick out and wear little children's cotton underwear," the suit says. 
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She was first allegedly abused in a pool house that same year when Epstein pulled her onto her his lap and began 
masturbating — claiming this was what "professionals" did. 
The attacks escalated, the court papers claim. The financier would regularly sexually assault her and force her to perform 
sex acts in Palm Beach, New York City and his New Mexico ranch, always traveling to the locations on his private plane 
dubbed the "Lolita Express." 
At 16, Epstein put Doe up in one of his apartments in New York City — near his own townhouse, where he would allegedly 
rape her the next year. 
MAIM 
Feds finally start 
investigating Jeffrey 
Epstein's gal pal Ghislaine 
Maxwell 
"In 1997, while at Epstein's townhouse on 9 East 71st Street in the City of New York. Epstein asked 17-year-old Doe if she had 
a boyfriend. Doe replied that she did not," the lawsuit reads. "Epstein responded that when she did have a boyfriend she 
would want the sex to be 'good' and that she should 'get it over with already; meaning lose her virginity." 
"Despite Doe's resistance, Epstein then pushed Doe down onto her stomach and raped her. From that point forward for 
several years in New York. Epstein raped Doe on multiple occasions," the papers claim, noting Maxwell was often present 
when the abuse took place. 
The court papers also claim Epstein introduced her to President Trump when she was 14 years old, allegedly elbowing 
Trump and saying, "This is a good one, right?" 
"Trump smiled and nodded in agreement." the suit states. 
A spokesperson for the president did not immediately return a request for comment. 
Doe is suing Epstein's estate, alleging sexual assault, sexual battery, false imprisonment and other charges. Her complaint 
joins over a dozen filed by other women claiming they were trafficked and abused by the multi-millionaire. 
Epstein was found dead in his jail cell in August while awaiting trial for sex trafficking. His death was officially ruled a suicide 
by hanging. 
Lawyers for Maxwell and Epstein's estate did not immediately return emails. 
FILED Uk, 
• 
COURTS. DONALD TRUMP. GHISLAINE MAXWELL JEFFREY EPSTEIN, LAWSUITS, PEDOPHILES, SEXUAL ABUSE, I/18/20 
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Epstein, Maxwell wanted me to have surrogate baby: Virginia 
Roberts 
March 22.2020 I 3:24pm 
Virginia Roberts Giuffre 
wham Farrington 
Former teen "sex slave" 
when they asked her, at g 
, 
pear mew sur 
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says she finally fled Jeffrey Epstein and Ghislaine Maxwell after three years, 
ogate baby. 
Epstein's former gal pal 
sues his estate 
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has also accused Epstein of pimping her out to Prince Andrew when she was 
just 17, was revealed by her attorney, Bradley Edwards, in his new memoir, "Relentless Pursuit." 
"It was the final straw," Edwards writes in an excerpt published in the Daily Mail. 
"She knew she had to escape." 
FILED UNDER GHISLAINE MAXWELL JEFFREY EPSTEIN, PRINCE ANDREW, 
3/22/20 
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Socialite Ghislaine Maxwell 'groped a 16-year-old girl 
during a naked massage,' victims' lawyer says 
El dailvmail.co.ukThews/article-8163681/Socialite-Ghislaine-Maxwell-qroped-16-vear-old-airl-naked-massaae-victims-
lawyer-says.html 
March 28. 2020 
Socialite Ghislaine Maxwell 'groped a 16-year-old girl during a 
naked massage while Jeffrey Epstein watched,' lawyer who 
dedicated his life to nailing Prince Andrew's paedophile friend 
claims in new book 
• Ghislaine Maxwell, 58, allegedly sexually assaulted i6-year-old 
• It reportedly happened at paedophile Epstein's 7,500-acre New Mexico 
ranch 
• A lawyer for more than 20 of Epstein's victims has made the allegation 
By Mark Hookham For The Mail On Sunday 
Published: 18:O3 EDT, 28 March 2O2O I Updated: 15:59 EDT, 2 July 2O2O 
• 
• 
• e-mail 
• 
713 shares 
Socialite Ghislaine Maxwell allegedly groped a teenage girl during a naked massage while 
paedophile Jeffrey Epstein watched, a new book claims. 
Maxwell, 58, allegedly sexually assaulted 16-year-old 
at Epstein's 7,5OO-acre 
ranch in New Mexico, according to the book by Bradley Edwards, a lawyer for more than 
2O of Epstein's victims. 
The book, from which we are summarising stories in The Mail on Sunday, details 
Maxwell's alleged role in recruiting and grooming underage girls for Epstein. According to 
some accounts, she was even involved in some of the abuse herself. 
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It raises serious questions as to why Maxwell, whose whereabouts have been a mystery for 
months, has never been charged with any wrongdoing. She has always maintained that 
allegations against her are abhorrent and untrue. 
The book also claims that: 
Maxwell, Epstein's ex-girlfriend, was at the wedding of former US President Bill 
Clinton's daughter Chelsea in July 2010, a year after Epstein was released from jail as 
a convicted sex offender; 
She loved to take nude photographs of girls and allegedly took many of the pictures 
displayed on the walls of Epstein's mansions. 
According to one witness, she felt `indebted' to Epstein for helping her following the 
mysterious death in 1991 of her father, disgraced tycoon Robert Maxwell; 
Epstein `wasn't beyond killing someone' to keep his sex addiction alive, the witness 
claimed. 
now 40, helped keep Epstein behind bars last July after giving evidence 
about her ordeal as a teenager during a bail hearing. The financier was found dead in his 
cell the following month. Ms 
is now suing Epstein's estate and Maxwell in the New 
York district court for damages. 
According to Ms 
testimony, detailed in the book, she was flown to the financier's 
vast Zorro Ranch after he offered to pay for her to attend a summer educational 
programme in Thailand. 
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Queen's 'favourite son' of having sex with her 
who has accused the 
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When will feds arrest Jeffrey Epstein `fixer' Ghislaine Maxwell? 
May 28. 2020 I 4:l7pm I Updated 
Jeffrey Epstein and Ghislaine Maxwell 
Patticit McMullan via Getty Images 
Nine months after Attorney General William Barr warned that Jeffrey Epstein's co-conspirators -should not rest easy: the 
pedophile's alleged madam. Ghislaine Maxwell. remains at large — and is using a potential criminal investigation to thwart 
civil action against her. 
Maxwell is currently a co-defendant in several civil cases brought by alleged Epstein sex-trafficking victims. 
Among them is 
lured to his New 
ho claims in her suit against Maxwell and the proprietors of Epstein's estate that she was 
emu:, rant as a teenager and sexually abused by the pair. 
According to the suit. Maxwell allegedly forced n 
undress in view of Epstein after promising to give her a massage. 
"Maxwell touched intimate parts of .Mody 
against her will for the sexual benefit of 
Maxwell and Epstein." the suit states. "Maxwell exposed 
reasts and groped her," it adds. 
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