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Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 31 of 32 In contrast, there is no basis for a finding of good cause to protect the content of the Requested Documents, all of which concern Ms. Giuffre’s own allegations. She cannot credibly claim that disclosure will cause her “annoyance, embarrassment, oppression, or undue burden or expense,” see Fed. R. Civ. P. 26(c). Indeed, Ms. Giuffre has waived any claimed to confidentiality. She has publicly filed her accusations of sexual misconduct against an array of individuals, including Professor Dershowitz, in at least two lawsuits besides this one. Dershowitz Decl. {{ 10-12, 15-20. She has sold her story to the media and sat for extensive interviews with Ms. Churcher and other reporters about the very same allegations that are the subject of the Requested Documents. Jd. §{] 13, 26-27. She even “agreed to waive her anonymity” in order to disseminate her story publicly. Sharon Churcher, Exclusive: Girl at Center of Underage Sex Procurement Case That Scandalised America Describes How She Was Introduced to the Prince, MAIL ON SUNDAY, Feb. 27, 2011. More recently, Ms. Giuffre sat for an interview with ABC News, hoping to increase public interest in her allegations. Dershowitz Decl. 4] 27. Although the interview has not yet aired, it could be broadcast at any time, likely repeating once again the same allegations for which Ms. Giuffre has claimed confidentiality in the context of litigation discovery. See id. And her lawyers have continued to give interviews insinuating Professor Dershowitz’s guilt even after reaching a settlement with him and agreeing to release a public statement withdrawing their own public filing of the accusations against him. See Dershowitz Decl., Ex. H. In short, disseminating the information contained in the Requested Documents, which she has designated “confidential” in the context of this lawsuit, has been Ms. Giuffre’s life’s work for years. Having made every effort to publicize these allegations for personal and commercial gain, Ms. Giuffre should not be permitted now to make an abrupt about-face and claim that they are entitled to this Court’s protection from public dissemination. 25