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Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 7 of 31 Indeed, the documents in question could hardly “confirm his absolute innocence.” DE 364 at 1. The documents do not directly bear on Ms. Giuffre’s sworn and detailed statements about how Dershowitz sexually abused her, statements that are corroborated by a mountain of supporting evidence.” Instead, according to Dershowitz, these materials create some sort of a web of circumstantial inferences suggesting his innocence. His attenuated reasoning hardly provides the kind of compelling reason needed to pierce the Protective Order. Instead, Dershowitz seeks these documents for the primary purpose of conducting a media blitz against Ms. Giuffre in advance of trial — clearly to assist his joint defense partner, Defendant Maxwell, by poisoning the jury pool in this case. Dershowitz has no legal basis for his request. The documents in questions are not judicial documents, and thus neither a First Amendment nor common law right of access applies. Moreover, both the parties in this case have long reasonably relied on the existing Protective Order. Under that order, numerous documents involving child sex abuse and other sensitive subjects have been placed under seal. If Dershowitz is permitted to cherry pick the documents that he finds favorable and extract them from the protective order to serve his purposes, it would seem only fair that Ms. Giuffre be permitted to lift the protective order from currently- confidential documents and testimony in the court file which would support her position. This Court entered the Protective Order “upon a showing of good cause.” Dershowitz is not a party to this litigation and provides no sound reason for modification. Accordingly, this Court should deny Dershowitz’s motion in its entirety. ? As an overview, Dershowitz, who touted Epstein as a close friend, flew on Jeffrey Epstein’s private jet 15 times from 1996 through 2006, which was during the time period that Jeffrey was actively assaulting a number of minor children. Twice Dershowitz flew with Sarah Kellen, who was Defendant’s right hand recruiter of these underage girls. McCawley Dec at 2, Dershowitz Flights. While Dershowitz said he was “never” in the places where Virginia was during the period of 2000 — 2002, public records directly contradict this statement and show that he actually had an apartment in New York not far from Epstein’s home for a year from 2000 — 2001. McCawley Dec. at 3. While there is mounting evidence to support Ms. Giuffre’s allegations of Dershowitz’s involvement, that issue is not something the Court needs to decide because this case is about Defendant Maxwell’s conduct, not Dershowitz. 2