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Case 1:15-cv-07433-LAP Document 1332-15 Filed 01/08/24 Page 2 of 11 Party Jane Doe 43 filed her own action against Jeffrey Epstein and others for violations of 18 U.S.C. § 1595 for engaging in commercial sex trafficking. Despite the fact that it is well settled that a Court should not consider documents beyond the four corners of the complaint in evaluating a Motion to Dismiss, the Epstein Defendants seek to utilize documents produced by Jane Doe 43 in this matter for purposes of supporting their Motion to Dismiss in the matter before Judge Koeltl. The Epstein Defendants argue that the materials can be used to establish that Jane Doe 43’s claims should be barred because they are outside the ten (10) year statute of limitation period and also that they somehow establish that Epstein is not within the New York Court’s jurisdiction. Accordingly, the Epstein Defendants came before this Court seeking to intervene to gain access to documents that were marked confidential under the Protective Order. In an effort to avoid any unnecessary motion practice before this Court, Non-Party Jane Doe 43 and Virginia Giuffre agreed to the release of her deposition transcript and any of the documents that could remotely be related to the challenges to jurisdiction and statute of limitations (56 documents) which the Epstein Defendants desire to present at the Motion to Dismiss stage. The Epstein Defendants were not satisfied with the disclosure agreement, and are therefore before this Court seeking additional documents. At the outset, it is critical to note that the Court, in its November 2, 2016 order, has already held in this case that a non-party cannot seek to overturn the protective order as follows: “The Protective Order states that parties can object to the confidentiality designations: “A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice to the party designating the disputed information... it shall be the obligation of the party designating the information as CONFIDENTIAL to file an appropriate motion requesting that the Court determine whether the disputed information should be subject to the terms of this Protective Order.” This Court’s Protective Order does not allow for non-parties to challenge these designations.