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Case 1:15-cv-07433-LAP Document 1332-15 Filed 01/08/24 Page 6 of 11 about how Epstein continued to manipulate her in order to keep her compliant in his sexual trafficking ring. And, again, pursuant to this Court’s Orders, the movants do not have the right under the Protective Order to bring this motion. Il. The Disputed Documents Should Remain Protected Despite the fact that Jane Doe 43 and Virginia Giuffre agreed to release her deposition and 56 different documents, including communications from the time period she was abused by the Epstein Defendants, the Epstein Defendants are still insisting on coming before this Court to fight over the so-called “Disputed Documents” that the Epstein Defendants improperly and impermissibly seek to remove from this Court’s Protective Order. These documents have nothing to do with any of the Epstein Defendants’ alleged arguments in their Motion to Dismiss arguments that relate to jurisdiction and statute of limitations challenges. To the contrary, the Epstein Defendants are merely trying to publicly smear Jane Doe 43 by attaching salacious emails to a public filing, despite the fact that the documents have no relationship to the Motion to Dismiss. The “Disputed Documents” can be categorized in two groups. The first group is a collection of photographs of various people including Jane Doe 43, Epstein, Maxwell, and other females (Jane Doe 43 000204-235). The photographs are not dated and have no bearing on the statute of limitations or jurisdiction arguments that the Epstein Defendants want to make. The second group includes a series of 2016 communications that Jane Doe 43 had with a reporter (Jane Doe 43 000428-557). These communications are not relevant to either the issue of statute of limitations or the issue of whether the court has jurisdiction over the Epstein matter in New York. They do, however, include highly irrelevant items that could only serve the Epstein Defendants by smearing and embarrassing Jane Doe 43, such as pictures of Jane Doe 43 after a