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Case 1:15-cv-07433-LAP Document 1335-5 Filed 01/09/24 Page 7 of 12 her close relationship with Jeffrey Epstein and plotted with him to defame Ms. Giuffre. Defendant has also chosen to designate as confidential the fact that she has a DUI conviction," so that her own criminal activity for which she has been convicted is not in the media. IL. DISCUSSION Ms. Giuffre has not challenged any of Defendant’s self-serving confidentiality designations - designations that do not protect legitimate interests (such as trademark or copyright information) but rather conceal shameful aspects of Defendant’s life, including all the testimony regarding the specifics on just how she recruited underage girls for sex with convicted pedophile Jeffrey Epstein But now Defendant challenges Ms. Giuffre’s designation of a police report involving rape as confidential. The Court should not countenance the one-sided attempt at gamesmanship by Defendant (and Dershowitz), who use confidentiality designations as a shield to block release of information about Epstein’s sex trafficking while attempting to strike down Ms. Giuffre designations about such things as being sexually assaulted while a child. Given the extremity of the position she is staking out, it is unsurprising that Defendant’s entire brief cites no case law, and presents no argument to refute Ms. Giuffre’s case law. The material Defendant seeks to send to the press is exactly the type of information that Protective Orders are meant to protect, and this Court should deem these documents as confidential. A. The Court can Order that these Documents be Made Confidential Either Under the Existing Protective Order or Independent of the Protective Order Ms. Giuffre explained in detail why her application to the Court is timely filed under the Protective Order [DE 62], and will not burden the Court with a recitation of such details and arguments. The simple fact remains that these materials should remain confidential, and 4 See McCawley Dec. at Exhibit 4, Maxwell Dep. Tr. at 390:13-15 (April 22, 2016). 6