Giuffre_Maxwell_Batch4_p00368.png
Extracted Text (OCR)
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
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Extracted Information
Dates
Document Details
| 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 |