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Case 1:15-cv-07433-LAP Document 1335-5 Filed 01/09/24 Page 6 of 12 is not acting alone in this effort, but is teaming up with Alan Dershowitz’ to ask this Court to release additional documents (but, naturally, none of the condemning documents Defendant has marked confidential). Part of Defendant’s frantic attempt to discredit Ms. Giuffre is to publicly reveal that she was sexually assaulted as a 14 year old, yet announce to the world that she “cried rape,”"* and to humiliate her family (including three minor children) by publicizing she was the victim of domestic abuse in 2015. As the Court saw during its in camera review, Defendant and Mr. Gow previously exchanged emails about how to leak information to the press to discredit Ms. Giuffre by saying that she “cried rape” when she was 14 (GM_00577): From: Ross Gow Sent: Tuesday, February 24, 2015 3:36 AM To: G Max; Philip Barden Subject: VR cried rape - prior case dismissed as prosecutors found her ‘not credible’ Ghislaine Some helpful leakage... Defendant has been liberal with her own confidentiality designations. In fact, Defendant has even requested that significant parts of this Court’s Orders be treated as “confidential.” For example, when this Court issued its June 20, 2016, Order directing Defendant to turn over documents that she improperly claimed as “privileged,” Defendant redacted the public version of the Order to erase all reference to her extensive communications with her boyfriend, convicted pedophile Jeffrey Epstein. While seeking to publicize confidential information about Ms. Giuffre, Defendant apparently does not want the world not know that she continues to maintain ” Defendant has even filed an Affidavit from Dershowitz’s attorney which states that there is a common interest between them. Curiously, the name of Dershowitz’s attorney, as is the name of Dershowitz himself, is redacted in the public version of these briefs. See (DE 387). 8 As the Court saw during its in camera review, Defendant and Mr. Gow exchanged emails about how to discredit her by saying that she “cried rape” when she was 14. 5