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Case 1:15-cv-07433-LAP Document 1332-15 Filed 01/08/24 Page 7 of 11 suicide attempt. Those could only be used to publicly humiliate and intimidate her. Again, none of that evidence should be considered at the Motion to Dismiss stage. Of course, the Court need not reach such details for consideration on the instant motion as it has already held that non- parties cannot challenge the Protective Order. Il. The Court Should Not Modify the Protective Order as to These Documents The Court took care to have the parties enter into the Protective Order in this case given the sensitive nature of the sexual abuse allegations at issue. Jane Doe 43 courageously gave her testimony in this action, and voluntarily produced documents even though she was not subject to a subpoena in Spain. The documents that she produced contain sensitive information, and the Epstein Defendants have failed to set forth a sufficient basis justifying a modification to the Protective Order. As the Court is aware, even if the Epstein Defendants did set forth a sufficient basis, this Court still could not grant the relief sought because, as it previously held, non-parties cannot move the Court to modify the Protective Order. The Court need not reach any of the arguments put forth by these non-parties. This Court’s November 2, 2016 Order makes clear that a non-party, like Epstein here, who obtains Confidential materials only through his participation in this case, is bound by the terms of the Protective Order which only allows modification by a “party.” Order at 24-25. There is a “strong presumption against the modification of a protective order,” in the Second Circuit, and “orders should not be modified absent a showing of improvidence in the grant of the order or some extraordinary circumstance or compelling need.” Jn re Teligent, Inc., 640 F.3d 53, 59 (2d Cir. 2011); see also In re September 11 Litigation, 262 F.R.D. 274 (S.D.N.Y. 2009). The Second Circuit has been hesitant to permit modifications that might “unfairly disturb the legitimate expectations of the parties or deponents.” Dorsett v. County of