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Case 1:15-cv-07433-LAP Document 1332-15 Filed 01/08/24 Page 3 of 11 The Movant agreed to be bound by the provisions of the Protective Order in exchange for receiving the Requested Documents. Accordingly, he has agreed to the confidentiality restrictions placed on the documents, no matter what the documents contained so that he could be privy to all of the discovery in this case. He is thereby bound by its confidentiality provisions, as well as the provisions that only allows parties to bring challenges to the Protective Order.” November 2, 2016 Sealed Opinion (emphasis added). Similarly here, the Epstein Defendants only have possession of these documents because Epstein was a witness in this matter bound by the Protective Order. As such, he cannot move to release those documents because he is not a party to this action. Defendant Maxwell has not joined Epstein’s Motion. Accordingly, it is the law of the case that his motion must be denied. ARGUMENT It is well settled that a Court should not consider documents outside the four corners of the Complaint at the Motion to Dismiss stage. See, e.g., In re Giant Interactive Grp., Inc. Sec. Litig., 643 F. Supp. 2d 562, 573 (S.D.N.Y. 2009) (Sweet, J.) (Court not considering evidence outside of complaint in deciding motion to dismiss, denying motion) (“‘[T]he evidence advanced by Defendants is not within the four corners of the Complaint, and cannot be considered here.”” (citing Fonte v. Bd. of Managers of Cont'l Towers Condo., 848 F.2d 24, 25 (2d Cir. 1988))); Bill Diodato Photography LLC v. Avon Prod., Inc., No. 12 CIV. 847 RWS, 2012 WL 3240428, at *4 (S.D.N.Y. Aug. 7, 2012), on reconsideration, No. 12 CIV. 847 RWS, 2012 WL 4335164 (S.D.N.Y. Sept. 21, 2012) (Sweet, J.) (“A Rule 12(b)(6) motion to dismiss challenges only the face of the pleading. Thus, in deciding such a motion to dismiss, ‘the Court must limit its 999 analysis to the four corners of the complaint.’” (internal citations omitted)). Yet the Epstein Defendants seek to intervene in this case for the exact purpose of obtaining relief from documents marked as “confidential” to admittedly utilize in support of their Motion to Dismiss.