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Case 1:20-cr-00330-AJN Document 134 Filed 02/04/21 Page 9 of 23 this proposal, and it was never included in the Protective Order. Ex. A.” To the contrary, the order strictly limited the parties’ disposition of Confidential Material, including at the conclusion of the case. In particular, paragraph 12 of the order provided that: [alt 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 destruction. Ex. A { 12. B. Maxwell’s April and July 2016 depositions Relying on the confidentiality protections of the Protective Order, Maxwell declined to invoke her privilege against compulsory self-incrimination and agreed to testify at her April N fan) — On Qa. OQ ao} [) wm = cS. (oe) B — =) omy =" & Qa. OQ ao [) & ct. i) =) > Following the deposition, Giuffre moved to compel Maxwell to answer additional intimate and personal questions that she had previously declined to answer. In support of the motion, Boies Schiller assured the district court that “[s]uch questions are entirely appropriate in the discovery phase of this case, particularly where any answers will be maintained as confidential under the Protective Order in this case.” * This proposal was rejected because of justifiable concerns about the misuse and abuse of this information by plaintiff and her lawyers including the selection and misleading leaking of confidential material to the media, other false claimants, and the government. 4 DOJ-OGR- 00002356