Giuffre_Maxwell_Batch8_p00870.png

Case 1:15-cv-07433-LAP Document 1335-5 Filed 01/09/24 Page 2 of 12 Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this Reply in Support of her Motion for Protective Order and Motion for the Court to Direct Defendant to Disclose All Individuals to whom Defendant has Disseminated Confidential Information (DE 335). I. INTRODUCTION “The nature of this case concerns highly personal and sensitive information from both parties. In this action, both parties have sought and will seek confidential information in the course of discovery from the other party and from non-party witnesses. Release of such confidential information outside of the litigation could expose the parties to ‘annoyance, embarrassment, [and] oppression and result in significant injury to one or more of the parties’ business or privacy interests.” - Defendant, Ghislaine Maxwell, March 2, 2016! Less than six months after representing to this Court that this case involves “highly personal and sensitive information” warranting a broad protective order, Defendant now wants to publicize police reports concerning Ms. Giuffre - most of them from when she was a child, some of them concerning her being raped when only 14 years. Defendant’s challenge to Ms. Giuffre’s confidentiality designation is without merit, and it is for improper purposes. Therefore, it should be denied. Ms. Giuffre moved to maintain her confidentiality of highly sensitive documents. They are police reports involving Ms. Giuffre, including two police reports describing Ms. Giuffre as a fourteen-year-old victim of rape. Other police reports show her to be the victim of other crimes, including domestic violence. Defendant should not be allowed to make these police reports public, nor disseminate them to third parties. Defendant’s Response brief is devoid of any argument to allow her to make these documents public, and completely devoid of any case law. 'DE 38 at 1.