Giuffre_Maxwell_Batch7_p00289.png

Case 1:15-cv-07433-LAP Document 1332-15 Filed 01/08/24 Page 1 of 11 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. JOINT RESPONSE IN OPPOSITION TO PROPOSED INTERVENORS’ MOTION FOR LEAVE TO INTERVENE AND TO MODIFY THE PROTECTIVE ORDER Non-Party Jane Doe 43 in the captioned matter Jane Doe 43 v. Epstein, et al, No. 17 Civ. 616 (JGK) and Plaintiff Virginia Giuffre oppose the Proposed Intervenors’ Motion for Leave to Intervene and to Modify the Protective Order for the reasons set forth below. The Proposed Intervenors are two non-parties, Jeffrey Epstein and Leslie Groff (“Epstein Defendants”). PRELIMINARY STATEMENT This Court has twice held that non-parties, such as Jeffrey Epstein and Leslie Groff, cannot challenge this Court’s Protective Order. Therefore, the Court should summarily deny this motion. PROCEDURAL HISTORY On March 18, 2016, this Court entered a Protective Order (DE 62) for the privacy of the parties and deponents. Non-Party Jane Doe 43 was a fact witness and deponent in the Giuffre v. Maxwell case. She provided both deposition testimony and documents in this case which were designated as “confidential” under the terms of the Protective Order. On January 26, 2017, Non-