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Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 3of 27 To Be Filed Under Seal statutory and common law privacy concerns. (Dkt. No. 38 at 1.) Maxwell submitted a proposed form of order for Judge Sweet’s consideration. (Dkt. No. 39-1.) Giuffre represented that she “[did] not oppose the entrance [sic] of a Protective Order in this case, but [did] oppose a Protective Order in the form proposed by Defendant because it is overly broad and can lead to abuse and over designation[.]” (15-cv-7433, Dkt. No. 40 at 2.) Giuffre redlined Maxwell’s proposed protective order, deleting some provisions and (insofar as is relevant) adding language to paragraph 4— stating that confidential information “shall not be disclosed or used for any purpose except the preparation and trial of this case”’—to provide that confidential materials also could be disclosed with impunity “in any related matter, including but not limited to, investigations by law enforcement.” (15-cv-7433, Dkt. No. 41-5 § 4.) Maxwell opposed these modifications. (15-cv-7433, Dkt. No. 49.) At a hearing held on March 17, 2016, Judge Sweet concluded that “of course” a protective order was warranted. (Hrg. Tr., 15-cv-7433, Dkt. No. 66, at 4:25—3:1.) He gave no reason, but as Maxwell made her motion on the basis of privacy concerns, and Giuffre consented to entry of some form of a protective order for the same reason, I assume that Judge Sweet found privacy concerns to constitute good cause—which, given the subject matter of the lawsuit, would certainly have been warranted. Judge Sweet did not, however, resolve any of the disputes between the parties about what should or should not be in the order. Instead, he directed the parties to come up with an agreement to which everyone could stipulate. (/d. at 5:1—-12.) By the end of the hearing, Giuffre, who was eager to take Maxwell’s deposition, agreed to the form of order originally proposed by Maxwell. (id. 9:7-24.) The court agreed that it would “so order” Maxwell’s proposed version SDNY_GM_00000876 DOJ-OGR-00004926