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Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 4of27 To Be Filed Under Seal pursuant to the parties’ stipulation. Judge Sweet made no specific findings about any provision of that order. Ud. 9:25—10:6.) On March 18, 2016, the court formally entered the Protective Order. (15-cv-7433, Dkt. No. 62.) It provided, as such orders generally do, that any documents, materials and/or information designated confidential by the parties (the “Confidential Materials”) would be subject to the protections of, and could be disclosed to non-parties only in accordance with the terms of, the Protective Order. (Id. {§ 1-5.) The Protective Order also required all parties, at the conclusion of the case, either to return to the party who made the confidentiality designation, or (in the alternative) to destroy, each document and all copies of Confidential Materials in their possession. (Jc. { 5-7, 12.) This destruction obligation extended to the parties’ lawyers as well as to the parties themselves. (Jd. { 12.) The Protective Order specified that if Confidential Materials were contained in any document presented to the court, the filing “shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York.” (/d. $10.) The docket sheet in Giuffre v. Maxwell reveals that such motions were frequently made and routinely granted. As a result, a vast amount of the Giuffre Action was conducted, in effect, in secret—despite the fact that there was immense public interest in the matter. The Giuffre Action was settled and dismissed with prejudice pursuant to a joint stipulation for dismissal on May 25, 2017, which was shortly before the trial was to begin. (15- ev-7433, Dkt. No. 919.) The terms of the settlement remain confidential. (15-cv-7433, Dkt. No. 953 at 10.) SDNY_GM_00000877 DOJ-OGR-00004927