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"Stipulated Protective Order"
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EFTA00436222
Dataset 9
2011-03-31
1p
35w
Subject:
Fwd: RRA - Joint Ex-Parte Motion for
Stipulated Protective Order
(Epstein)
From:
Lesley Groff <MIMIII >
To:
Darren Indyke <Ma>
From: Lesley Groff <MIMIII > To: Darren Indyke <Ma> Subject: Fwd: RRA - Joint Ex-Parte Motion for
Stipulated Protective Order
(Epstein) Date: Thu, 31 Mar 2011 13:36:07 +0000 Attachments: Bankruptcy_
Stipulated_Protective_Order
(Jeffrey_Epstein).DOC Begin forwarded message: EFTA00436222
https://www.justice.gov/epstein/files/DataSet%209/EFTA00436222.pdf
EFTA00305074
Dataset 9
2011-03-30
3p
471w
…PARTE MOTION FOR ENTRY OF
STIPULATED PROTECTIVE ORDER
jExnedited Relief Requested) Herbert Stettin, the Chapter 11 Trustee ("Trustee") of the Debtor, Rothstein Rosenfeldt Adler, P.A. ("RRA"), and Jeffrey Epstein, a Plaintiff in the Circuit Court of the Fifteenth Judicial Circuit in and for Palm Beach County, Florida, Jeffrey Epstein v. Scott Rothstein, et al., Case No. 50 2009CA040800XXXXMB AG (hereinafter "Epstein"), by and through undersigned counsel, do hereby file this
Stipulated Protective Order
("
Stipulated Protective Order
") by and between…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00305074.pdf
EFTA00729507
Dataset 9
2010-05-18
3p
725w
…shall be disclosed to the Trustee who shall conduct a review for RRA's client's privilege before any RRA information may he published or otherwise used or distributed by the Receiving Party. D. The terms of any filed
Stipulated Protective Order
shall apply to any subsequent requests to the Trustee for Search of RRA information by that Requesting Party. 3. The Trustee agrees to keep any keywords or search criteria provided to the Trustee by any Requesting Party confidential…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00729507.pdf
EFTA01113724
Dataset 9
2011-03-30
3p
729w
…Filed 03/30/11 Page 1 of 3 ORDERED in the Southern District of Fl te in 4- ' aymond B. R nited States Bankruptcy rt UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION www.11sb.useotirts.gov CASE NO.: 09-34791 -RBR Chapter I I IN RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. AMENDED
STIPULATED PROTECTIVE ORDER
BY AND BETWEEN TRUSTEE AND CREDITORS Herbert Stettin, the Chapter I I Trustee ("Trustee") of the Debtor, Rothstein Rosenfeldt Adler…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01113724.pdf
EFTA00593799
Dataset 9
4p
683w
…www.flsb.uscourts.gov CASE NO.: 09-34791-RBR Chapter 11 WI RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. JOINT EX PARTE MOTION FOR ENTRY OF
STIPULATED PROTECTIVE ORDER
(Expedited Relief Requested) Herbert Stettin, the Chapter 11 Trustee ("Trustee") of the Debtor, Rothstein RosehfeldtAdler, P.A. ("RRA"), and Jeffrey Epstein, by and through this undersigned counsel, Fowler White Burnett, move for the entry of
Stipulated Protective Order
("
Stipulated Protective Order
") by and between the Trustee and Mr. Epstein's counsel…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00593799.pdf
EFTA01176822
Dataset 9
2012-05-17
12p
2,426w
…s Order and Modified Order. 3. The Trustee and Epstein are requesting expedited relief so that Epstein can quickly begin the process of reviewing and analyzing any responsive documents. WHEREFORE, the Trustee and Epstein jointly move for the entry of the
Stipulated Protective Order
and Agreed Confidentiality Order by and Between Trustee and Epstein attached hereto as Exhibits "A" & "B", and for any and all other relief this Court deems just and equitable. Dated: May 17, 2012. Respectfully submitted: s…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01176822.pdf
EFTA00611614
Dataset 9
2009-10-23
1p
205w
…As you know, these are Mr. Rodgers' personal documents. Pursuant to your agreement with Bob Critton about limiting the time period covered by the subpoena, I am prepared to provide these documents to you, provided you agree to a
stipulated protective order
containing the following conditions. First, the information contained in Mr. Rodgers' pilot logs for 1998-2005 will be used solely for purposes of the litigation in which Mr. Rodgers was subpoenaed as a witness. Second, the information will…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00611614.pdf
EFTA00593803
Dataset 9
2010-05-18
3p
715w
ORDERED in the Southern District of Florida on Raymond B. Ray, Judge United States Bankruptcy Court UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION www.flsb.uscourts.gov CASE NO.: 09-34791-RBR Chapter 11 IN RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor.
STIPULATED PROTECTIVE ORDER
BY AND BETWEEN TRUSTEE AND CREDITORS Herbert Stettin, the Chapter 11 Trustee ("Trustee") of the Debtor, Rothstein RosehfeldtAdler, P.A. ("RRA"), and Jeffrey Epstein, by and through this undersigned counsel, Fowler…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00593803.pdf
EFTA00731649
Dataset 9
2010-05-18
3p
709w
ORDERED in the Southern District of Florida on Raymond B. Ray, Judge United States Bankruptcy Court UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION www.flsb.uscourts.gov CASE NO.: 09-34791-RBR Chapter 11 IN RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor.
STIPULATED PROTECTIVE ORDER
BY AND BETWEEN TRUSTEE AND CREDITORS Herbert Stettin, the Chapter 11 Trustee ("Trustee") of the Debtor, Rothstein RosehfeldtAdler, P.A. ("RRA"), and Jeffrey Epstein, by and through this undersigned counsel, Fowler…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00731649.pdf
EFTA00018749
Dataset 8
2020-08-17
8p
3,922w
…a statement from Ms. Maxwell's attorney-hired press agent generally denying as "untrue" and "obvious lies'as allegations that Ms. Maxwell participated in a scheme causing her to be "sexually abused and trafficked" by Jeffrey Epstein. Given the amount of personal, confidential material and information sought in discovery, the district court entered a
stipulated Protective Order
protecting confidential information from public disclosure. See Giuffre v. Maxwell, 15-cv- 7433 (Doc. # 62).4 The language agreed upon, and made an…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00018749.pdf
EFTA00011452
Dataset 8
2017-06-30
23p
6,031w
…information about financial and sexual matters. Brown, 929 F.3d at 48 n.22. Given the intimate and highly confidential nature of the discovery exchanged between the parties, the district court entered a
stipulated Protective Order
. See Ex. A. The Protective Order included a mechanism for one party to challenge another party's confidentiality designation (such a challenge never occurred) and provided that it did not apply to any information or material disclosed at trial. (Because the case settled before…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00011452.pdf
EFTA00029077
Dataset 8
2017-06-30
23p
5,979w
…information about financial and sexual matters. Brown, 929 F.3d at 48 n.22. Given the intimate and highly confidential nature of the discovery exchanged between the parties, the district court entered a
stipulated Protective Order
. See Ex. A. The Protective Order included a mechanism for one party to challenge another party's confidentiality designation (such a challenge never occurred) and provided that it did not apply to any information or material disclosed at trial. (Because the case settled before…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00029077.pdf
EFTA00029816
Dataset 8
2017-06-30
23p
5,973w
…information about financial and sexual matters. Brown, 929 F.3d at 48 n.22. Given the intimate and highly confidential nature of the discovery exchanged between the parties, the district court entered a
stipulated Protective Order
. See Ex. A. The Protective Order included a mechanism for one party to challenge another party's confidentiality designation (such a challenge never occurred) and provided that it did not apply to any information or material disclosed at trial. (Because the case settled before…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00029816.pdf
EFTA00086658
Dataset 9
2017-06-30
23p
6,016w
…information about financial and sexual matters. Brown, 929 F.3d at 48 n.22. Given the intimate and highly confidential nature of the discovery exchanged between the parties, the district court entered a
stipulated Protective Order
. See Ex. A. The Protective Order included a mechanism for one party to challenge another party's confidentiality designation (such a challenge never occurred) and provided that it did not apply to any information or material disclosed at trial. (Because the case settled before…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00086658.pdf
EFTA00074903
Dataset 9
2020-07-31
38p
8,325w
…But Ms. Maxwell sat for the deposition and was compelled to answer numerous personal, sensitive, and allegedly incriminatory questions only after the plaintiff and the district court, through a
stipulated Protective Order
, guaranteed the confidentiality of her answers. As this Court has long recognized, and as this case shows, "witnesses might be expected frequently to refuse to testify pursuant to protective orders if their testimony were to be made available to the Government for criminal investigatory purposes in disregard of…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00074903.pdf
EFTA00075477
Dataset 9
2020-08-20
74p
15,469w
…But Ms. Maxwell sat for her deposition and was compelled to answer numerous personal, sensitive, and allegedly incriminatory questions only after the plaintiff and the district court, through a
stipulated Protective Order
, guaranteed the confidentiality of her answers. As this Court long ago recognized, and as this case shows, "witnesses might be expected frequently to refuse to testify pursuant to protective orders if their testimony were to be made available to the Government for criminal investigatory purposes in disregard of…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00075477.pdf
EFTA01069715
Dataset 9
2011-02-17
16p
3,629w
…17 have to respond to a couple of things. 18 First of all, there was an outstanding 19 subpoena of the bankruptcy trustee from Razor 20 Back. Every time someone sends a subpoena to the 21 bankruptcy trustee, the trustee either enters into 22 a
stipulated protective order
or we go forward 23 with Judge Rey, every time there is a subpoena. 24 Now there are two, as I said before, there 25 are two other sets of documents that…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01069715.pdf
EFTA00726673
Dataset 9
2010-07-23
5p
1,006w
…disputes in accordance with the CPLR. (It is not intended that procedural discovery rules contained in the CPLR be followed but rather that the Rules shall provide a guide for the adequacy of production of documents and matters of privilege.) 9.
Stipulated Protective Order
. Counsel are invited to enter into a
stipulated protective order
concerning the confidentiality of documents produced in this proceeding. The Arbitrator will provide assistance if required. 10. Exchange of Information. The parties shall exchange all documentary…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00726673.pdf
EFTA01108511
Dataset 9
2012-09-04
20p
5,689w
…C. Documents shall not be withheld on the grounds that they contain highly sensitive or confidential information, but may be produced pursuant to the terms of a
Stipulated Protective Order
Regarding the Disclosure and Use of Discovery Materials entered in this case. 3 EFTA01108519 REQUESTS FOR PRODUCTION All documents concerning the K(112 Patent. 2. All documents concerning the prosecution of the KGR Patent before the United States Patent and Trademark Office and/or any foreign patent ollice(s). 3…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01108511.pdf
EFTA01069308
Dataset 9
2010-04-16
86p
14,016w
…shall be disclosed to the Trustee who shall conduct a review for RRA's client's privilege before any RRA information may be published or otherwise used or distributed by the Receiving Party. D. The terms of any filed
Stipulated Protective Order
shall apply to any subsequent requests to the Trustee for Search of RRA information by that Requesting Party. 3. The Trustee agrees to keep any keywords or search criteria provided to the Trustee by any Requesting Party confidential…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01069308.pdf
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