Giuffre_Maxwell_Batch8_p00877.png

Case 1:15-cv-07433-LAP Document 1335-5 Filed 01/09/24 Page 9 of 12 redacted information, those concerns should be allayed by the September 13, 2007 Stipulated Protective Order”). In this case, unlike Maxwell who has refused to produce documents, Ms. Giuffre has produced a number of documents including turning over personal, embarrassing documents that bear no relation to the claim at issue in this case. Indeed, Defendant has procured other documents with the same issues, including those documenting her being raped as a 14 year old and being beaten by her husband, the father of her three minor children. These are the types of documents for which confidentiality treatment during pre-trial proceedings is appropriate. B. Defendant’s Challenge of these Materials (and her Joint Defense Partner’s Challenge of Other Materials) Frustrate this Court’s Ability to Resolve the Claim at Issue, and is a Waste of Judicial Economy Defendant and her joint defense partner, Dershowitz, for no apparent reason than their media smear campaign, are now tying-up this Court’s docket, asking the Court to engage in a document-by-document determination of confidentiality of the discovery in this case. This is a waste of judicial resources, as it in no way furthers the resolution of the claim before this court. Cf. Inre Terrorist Attacks on September 11, 2001, 454 F.Supp.2d 220, 223 (S.D.N.Y.2006) (“document-by-document confidentiality determinations . .. would impose an enormous burden upon the Court and severely hinder its progress toward resolution of pretrial matters”). Moreover, should Defendant and her joint defense partner prevail in these baseless efforts, Ms. Giuffre would be forced to apply to the Court to lift the confidentiality designations from parallel discovery materials in this case that refute what Defendant and her proxies say in the media (materials that are present in abundance in this case). None of this motion practice aids in the resolution of the claim before this Court, but would merely frustrate that resolution. Accordingly, the Court should grant Ms. Giuffre’s motion.