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Case 1:15-cv-07433-LAP Document 1332-17 Filed 01/08/24 Page 2 of 13 Defendant Ghislaine Maxwell, through her counsel, moves for an Order to Show Cause requiring plaintiff Virginia Giuffre and her lawyers to state why this Court should not impose sanctions for their failure to comply with this Court’s Protective Order (Doc.62) and Opinion issued on November 14, 2017. INTRODUCTION This Court entered a Protective Order that governs the parties’ use and disposition of documents designated as “Confidential” (“Confidential Materials”). The Protective Order prohibits the use of the materials in any other case, and requires the parties to return or destroy the materials at the conclusion of this case. This case concluded in May 2017. Despite our requests, Ms. Giuffre’s lawyers have refused to return or destroy the Confidential Materials. Instead, they have indicated they wish to use the Confidential Materials in another case they are pursuing. The Protective Order on which all the parties relied to disclose and produce Confidential Materials is unambiguous about the use and return or destruction of Confidential Materials. This Court should issue an Order to Show Cause. FACTUAL BACKGROUND Ms. Giuffre sought to convert her defamation action into a lawsuit for child “sexual abuse” and “sexual trafficking” of children. Toward that end, she made numerous allegations of sexual conduct involving herself, Jeffrey Epstein, Ms. Maxwell, and dozens of others, including numerous prominent men. In preparation to litigate Ms. Giuffre’s factual allegations, the parties sought and obtained from each other and non-parties a wide range of highly sensitive, personal and confidential information about themselves and non-parties. This Protective Order. To facilitate disclosures and discovery the Court entered a Protective Order allowing parties to disclose and produce “confidential’”-designated materials 1