Case 1:15-cv-07433-LAP Document 1199-1 Filed 01/27/21 Page 1 of 13 United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. MOTION FOR PROTECTIVE ORDER AND MOTION FOR THE COURT TO DIRECT DEFENDANT TO DISCLOSE ALL INDIVIDUALS TO WHOM DEFENDANT HAS DISSEMINATED CONFIDENTIAL INFORMATION Plaintiff, M=, by and through her undersigned counsel, hereby files this Motion for Protective Order and Motion for the Court to Direct Defendant to Disclose All Individuals to Whom Defendant has Disseminated Confidential Information pursuant to this Court's Protective Order (DE 62). wherein the Court allowed various documents to be maintained as confidential. Pursuant to the Court's Protective Order, marked as confidential highly sensitive documents and Defendant is now challenging that designation. Defendant objects to maintaining as confidential police reports involving including two police reports describing as a fourteen-year-old victim of rape. Other police reports show her to be the victim of other crimes, including domestic violence. Defendant should not be allowed to make these police reports public, nor disseminate them to third parties. They contain personal, sensitive, and embarrassing information. Many of them also concern minors and a victim of sexual assault; therefore, they are protected by various state statutes. requests that this Court maintain the confidentiality designations over these police reports and direct the Defendant to disclose all the recipients of the 1 EFTA02784749