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Case 1:15-cv-07433-LAP Document 1332-15 Filed 01/08/24 Page 9 of 11 Notably, the cases that the Epstein Defendants relies upon are inapposite. None of the cases that the Epstein Defendants cite involve the modification of a protective order for purposes of a defendant moving to dismiss a different case. More specifically, none of the cases that they cite relate to a protective order in a sexual abuse case. In Jnt’l Equity Investments, Inc. v. Opportunity Equity Partners Ltd., No. 05 CIV. 2745 JGK RLE, 2010 WL 779314, at *4 (S.D.N.Y. Mar. 2, 2010), the court granted the motion to intervene, but denied the motion to modify the confidentiality order, just as this Court has done two times before. In Charter Oak Fire Ins. Co. v. Electrolux Home Prods., Inc., 287 F.R.D. 130, 134 (E.D.N.Y. 2012), the plaintiff, not a third-party, moved to modify the order for a separate third-party in another case. In Gambale v. Deutsche Bank AG, 377 F.3d 133 (2d Cir. 2004), the court sua sponte publicly disclosed settlement terms. Jn re Ethylene Propylene Diene Monomer (EPDM) Antitrust Litig., 255 F.R.D. 308, 313 (D. Conn. 2009) involves a Canadian class action lawsuit that is virtually identical to its American counterpart. And in Jn re Visa Check/MasterMoney Antitrust Litig., 190 F.R.D. 309 (E.D.N.Y. 2000), the United States Department of Justice sought to intervene in an antitrust case. Finally, “a litigant's purpose in seeking modification of an existing protective order is also relevant for determining whether to grant a modification. Requests to modify protective orders so that the public may access discovery materials is arguably subject to a more stringent presumption against modification because there is no public right of access to discovery materials.” Dorsett, 289 F.R.D. at 65 (E.D.N.Y. 2012). There can be no legitimate purpose for the movants seeking pictures of Jane Doe 43 after her attempted suicide and these are documents they can seek through the normal courses of discovery before Judge Koeltl. As with other non- party attempted intervenors, the Epstein Defendants are seeking to humiliate and embarrass Jane