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Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 30 of 32 promotes efficiency in complex civil discovery, it strongly weakens the parties’ claim to a reasonable expectation that every document marked confidential will remain subject to a Rule 26(c) order indefinitely. See EPDM, 255 F.R.D. at 319. “Finally, the nature of the reliance on the Order weighs in favor of modification because there is no indication that the [parties] relied on the Order to produce documents they would not have otherwise disclosed.” Tradewinds Airlines, 2016 WL 3951181, at *2. Indeed, Ms. Giuffre could not reasonably have believed that she could avoid disclosing her own descriptions of, and communications about, the very subject matter of this lawsuit, which she commenced. See Lugosch, 435 F.3d at 125. Even if the parties’ reliance on the Protective Order could be deemed reasonable, which it cannot, Professor Dershowitz would handily satisfy TheStreet.com’s requirement of a compelling need or extraordinary circumstance. First, as one Court in this district explained recently, “courts within this circuit have found there to be a ‘compelling need’ or ‘extraordinary circumstance’ warranting modification where a blanket protective order is entered without a showing of good cause.” Tradewinds Airlines, 2016 WL 3951181, at *2 (collecting authorities). More importantly, under the circumstances, Professor Dershowitz’s need for the Requested Documents is undeniable. They strongly corroborate his denials of the sexual abuse allegations Ms. Giuffre belatedly levied against him, which were themselves first presented in documents filed publicly on a federal court docket. Dershowitz Decl. § 43. Professor Dershowitz has a compelling need to use all available evidence to defend himself against Ms. Giuffre’s allegations, which have persisted despite a thorough investigation exonerating him and continue to be republished in the media. Dershowitz Decl. ff 16, 18, 45. Professor Dershowitz will also use the Requested Documents to defend against a sanctions motion that is pending in a state court in Florida, providing an independent basis to modify the Protective Order. See id. § 46. 24