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Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 6 of 31 L INTRODUCTION The Court has before it a request from a non-party (Alan Dershowitz) to intervene in this case for the purpose of extracting and publicizing several emails and a draft manuscript from the Protective Order that has long been entered in this case. Dershowitz does not seek public access of these documents for the legitimate purpose of informing the public on this Court’s adjudication of its Article III powers. Instead, Dershowitz make clear that his purpose is to advance his own agenda, and continue to wage his media war on Ms. Giuffre, as he has already appeared on national news calling her a “prostitute” and a “bad mother.”! This is not the typical intervention case where a non-party seeks documents it lacks access to, or where a news organization seeks to inform the public on court proceedings. Here, Alan Dershowitz seeks to inject himself into this litigation for the wrongful purpose of conducting a public smear campaign of Ms. Giuffre. He has no interests beyond his own. And, he has already violated another court order directing him to stop wrongfully leaking confidential information to the media. Unsurprisingly, Dershowitz’s motion fails to cite a single case in which a court granted a non-party, who already possessed the sealed documents in dispute, the right to freely disseminate those documents in the public domain for self-serving purposes. His motion for permissive intervention is committed to the discretion of the Court, and the Court should deny it. Fed. R. Civ. P. 24(b)(3); Liz Claiborne, Inc. v. Mademoiselle Knitwear, Inc., 1996 WL 346352, at *4 (S.D.N.Y. June 26, 1996) (Sweet, J.) (denying leave to intervene); Levin v. U.S., 633 Fed. Appx. 69, 70 (2nd Cir. 2016) (affirming denial of motion to intervene, “Tb]ecause of the fact-intensive nature of an intervention decision, we review for ‘abuse of discretion’ a district court's order denying intervention . . . by permission.”) ' McCawley Dec. at Exhibit 1, Local 10 News, January 22, 2015. 1