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Case 1:15-cv-07433-LAP Document 1335-5 Filed 01/09/24 Page 10 of 12 C. Details Concerning Ms. Giuffre’s Rape as a 14 Year Old Are Only in The Public Realm Because, Upon Information and Belief, Defendant and/or Her Joint Defense Partners Previously Fed Them to The Media Defendant incorporated into her Response brief the media inquiry about Ms. Giuffre’s sexual assault and Sigrid McCawley’s response made on Ms. Giuffre’s behalf. This exchange illustrates exactly why Ms. Giuffre’s motion should be granted. The Court has seen the email from Ross Gow, Defendant’s public relations agent, informing her of the strategy of leaking the information to the press for the purpose of discrediting Ms. Giuffre by falsely claiming that she “cried rape” as a 14 year old. Unsurprisingly, the media was then tipped off to Defendant’s false and twisted version of the events, to which Ms. McCawley made a response. The Court has seen Defendant’s play book in action. Significantly, there is not a single word in Defendant’s brief refuting the fact that she challenges this confidentiality designation for improper purposes. II. CONCLUSION Ms. Giuffre was a child victim of sexual abuse, which is undisputed. Upon Defendant’s own motion, this Court entered a Protective Order in this matter. Ms. Giuffre has shown good cause for confidentiality of the materials at issue. Therefore, the Court should hold that these materials are confidential. This Court should also direct Defendant to disclose all the individuals to whom she has already disseminated the material at issue, and direct the Defendant to recall such material forthwith. DATED: August 23, 2016. Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Meredith Schultz Sigrid McCawley (Pro Hac Vice) S See GM_00577, above.