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Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 25 of 32 major importance to the administration of justice, then discovery motions and hearings fall within the ambit of this right. Mokhiber v. Davis, 537 A.2d 1100, 1112 (D.C. Ct. App. 1988) (internal quotation marks and citations omitted). Courts in this district have repeatedly recognized that filings submitted in connection with a motion to alter the pace or schedule of litigation are subject to public access. See, e.g., Lenart v. Coach Inc., 131 F. Supp. 3d 61, 72 (S.D.N.Y. 2015) (applying presumption of public access to “papers filed in connection with [a] motion to stay’”’); Skyline Steel, LLC v. PilePro, LLC, No. 13 Civ. 8171, 2015 WL 556545, at *4 (S.D.N.Y. Feb. 9, 2015) (same). “While adjudication of the ultimate merits of the case arguably triggers the highest degree of protection against sealing, this does not imply that motion papers addressed to a discovery dispute do not trigger the public-access presumption.” Jn re Omnicom Grp., 2006 WL 3016311, at *4. Because the Requested Documents were submitted by the parties in connection with discovery motions to be adjudicated by the Court, “those documents are entitled to the strongest presumption of public access.” Jn re Gushlak, 2012 WL 3683514, at *4. 2. There Are No Countervailing Interests That Outweigh the Right of Access The limited unsealing Professor Dershowitz seeks threatens none of the harms courts have recognized as sufficient to outweigh the right of access to judicial documents. As an initial matter, Professor Dershowitz seeks to reveal unflattering (and false) statements about himself. Thus, the general rule “that the common law right of access is qualified by recognition of the privacy rights of the persons whose intimate relations may thereby be disclosed,” Jn re Newsday, Inc., 895 F.2d 74, 79 (2d Cir. 1990), has no application. Nor does Ms. Giuffre possess any claim to privacy concerning the information Professor Dershowitz seeks to unseal. The Requested Documents discuss her allegations against a number of public figures, and relate to the preparation of a book manuscript with the goal of international publication and distribution. 19