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Source: GIUFFRE_MAXWELL  •  Size: 340.7 KB  •  OCR Confidence: 94.8%
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Case 1:15-cv-07433-LAP Document 1328-20 Filed 01/05/24 Page 11 of 14 Plaintiff has not cited any authority for the redaction of information from the Colorado police reports. IL. PLAINTIFF HAS WAIVED ANY ARGUMENT AS TO CONFIDENTIALITY A. Plaintiff Failed to Timely Move this Court to Uphold Her Designation of the Documents as Confidential The Protective Order in this case puts the onus on the person seeking a “Confidential” designation to either (a) resolve the matter with the opposing party, or (b) seek Court resolution. The Protective Order at § 11 provides: “Tf the parties cannot resolve the objection within ten (10) business days after the time the notice is received, it shall be the obligation of the party designating the information as CONFIDENTIAL to file an appropriate motion requesting that the Court determine whether the disputed information should be subject to the terms of this Protective Order. [f such a motion is timely filed, the disputed information shall be treated as CONFIDENTIAL under the terms of this Protective Order until the Court rules on the motion. Jf the designating party fails to file such a motion within the prescribed time, the disputed information shall lose its designation as CONFIDENTIAL and shall not thereafter be treated as CONFIDENTIAL in accordance with this Protective Order.” (Doc. # 62) It is undisputed that the defense challenged Plaintiff's designation of the materials as Confidential on May 18, 2016 and it is also undisputed that the parties could not resolve the objection within ten days after notice of the objection was received. Plaintiff did not file a motion requesting the Court to determine whether the material should be subject to the Protective Order for three months, hence, she did not file such a motion within the prescribed time, and the Protective Order now commands that the “disputed information shall lose its designation as Confidential” and “shall not thereafter be treated as Confidential.” Id. B. Plaintiff’s Counsel Has Repeatedly and Publicly Filed In This Case Numerous Publicly Available Police Reports With Redacted Juvenile Information In complete contradiction to her legal position in this Motion, Plaintiff and her counsel have repeatedly filed in public documents associated with this case, police reports from Florida 9

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Filename Giuffre_Maxwell_Batch4_p00368.png
File Size 340.7 KB
OCR Confidence 94.8%
Has Readable Text Yes
Text Length 2,337 characters
Indexed 2026-02-04 12:42:07.950858