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Case 1:15-cv-07433-LAP Document 1332-17 Filed 01/08/24 Page 4 of 13 The attempts by non-parties to gain access to Confidential Materials. Four sets of non-parties have sought access to various Confidential Materials submitted to the Court in various filings. In August 2016 Alan Dershowitz requested unsealing of portions of a brief filed in connection with a motion to quash, discrete emails filed with the motion, and the manuscript of Ms. Giuffre’s memoir filed with another motion. Doc.364, at 1-2. The Court denied the motion to unseal. Sealed Op., at 15-25 (Nov. 2, 2016). The Court noted Mr. Dershowitz sought to use the materials “in a media campaign to make public a selected portion of the discovery in this action to defend himself not in this court but in the court of public opinion.” /d. 21 (internal quotations and citation omitted). If his motion were granted, the Court observed, “the Protective Order will be selectively deployed and in the interest of reciprocity destroyed.” /d. at 21-22. The Court concluded: “Tt is presumptively unfair for courts to modify protective orders which assure confidentiality and upon which the parties have reasonably relied. . . . [T]he Second Circuit determined that ‘absent a showing of improvidence in . . . [a] protective order or some extraordinary circumstance or compelling need... a witness should be entitled to rely upon the enforceability of a protective order against any third parties.’” In this case, the parties and multiple other deponents have relied on this Court’s Protective Order in giving testimony and producing documents... . Id. at 23 (quoting Dorsett v. City of Nassau, 289 F.R.D. 54, 64 (E.D.N.Y. 2012) (quoting Martindell v. Int’l Tel. & Tel. Corp., 594 F.2d 291, 296 (2d Cir. 1979))). Mr. Dershowitz filed an appeal (Doc.504), which is pending. In January 2017 a purported journalist Michael Cernovich requested unsealing of Ms. Maxwell’s summary judgment brief, her attorney’s declaration in support of the summary judgment motion, and any “pleadings, memoranda, declarations, exhibits, orders, and other documents filed or to be filed” in connection with the summary judgment motion. Doc.551, at 2. 3