…agree to unseal the identities of non-party Does where that information is still sealed in Maxwell: As used in this Protective Order, the term “Confidential Information” includes (i) private financial information, such as tax records and bank account numbers…
…15 15. Defendant also demands items like personal financial documents from this non-party including payments she received from convicted sex offender Jeffrey Epstein and the men he “lent” this minor child out to from 1999 – 2002. See Exhibit 6…
…encourage 15 Plaintiff to fabricate facts or portions of her stories; and 5) they were not motivated in taking their actions by potential financial gain . Edwards and Cassell point to both communications with Plaintiff and their own work product in…