UNITED STATES DISTRICT COURT-4.5 SOUT-5.4HERN DISTRICT OF YORK VIRGINIA GIUFFRE,-5.9 Plaintiff against GHISLAINE MAXWELL Defendant No Civ RW8.7S REPLY M-6.7E1.7MORANDUM OF LAW IN FURTHER SUPPORT OF PROPOSED INTERVENOR ALAN DERSHOWITZ11.9?-2.1S MOTION FOR PERMISSIVE INTERVENTION AND UNSEALING OF JUDICIAL DOCUMENTS OR IN THE ALTERNATIVE MODIFICATI-6O-2.8N OF PROTECTIVE ORDER Em8.4ery Celli Brinckerhof8.8f Abady LLP Fifth Avenue th Floor New York New York Case Document Filed Page of i TABLE OF CONTENTS PAGE TABLE OF AUTHORITIES i PRELIMINARY STATEMENT ARGUMENT I THE PUBLI-7.5C HAS A RIGHT TO ACCESS THE REQUESTED DOCUMENTS A The Requested Docum8e-1nts Are Judicial Docum8e-1nts to W8.8h.2ich a Strong Presum7.8ption of Access Applies Professor Dershowitz?s Motives Are Proper and Are Irrelevant Anyway II MS GIUFFRE HAS NO BASIS FOR CONTINUE-5.1D SECRECY.5 I EVEN IF THE REQUESTED DOCUMENTS ARE NOT PRESUMPTIVELY PUBLIC THERE IS NO BASIS 4.9FOR A PROTECTIVE ORDER A The Presumption Against Modification of a Protective Order Does Not Apply Even If the Presum8ption Applied Extraordinary Circum8stances Exist to Justify Modification CONCLUSI-7.1ON Case Document Filed Page of ii TABLE OF AUTHORITIES Cases Alexander Interactive Inc Adorama Inc No Civ WL S.D.N.Y Sept Allen City of N.Y Supp 2d S.D.N.Y Anderson Cryovac In5.4c F.2d 1st Cir Atmospherics Ltd Hansen A.D.3d 2d Dep?t Chicago Tribune Co Bridgestone/Firestone Inc F.3d 11th Cir Cohen Cohen No Civ S.D.N.Y June Fournier Erickson Supp 2d S.D.N.Y Gucci Am Inc Guess Inc No Civ WL S.D.N.Y Apr In re Agent Orange Prod Liab Litig F.2d 2d Cir In re EPDM Antitrust Litig F.R.D Conn In re Gushla5.6k No MC WL July In re Omnicom Grp Inc Secs Litig No Civ WL S.D.N.Y Oct JetBlue A5.5i-2.5rways Corp Helferich Patent Licensing LLC Supp 2d E.D.N.Y Leucadia Inc Applied Extrusion T6.6echs Inc F.2d 3d Cir Lown Salvation Army Inc No Civ S.D.N.Y Oct Case Document Filed Page of i Lugosch Pyramid Co of Onondaga F.3d 2d Cir Lytle JPMorgan Chase Supp 2d S.D.N.Y Mokhiber Davis A.2d D.C Newsday LLC Cnty of Nassau F.3d Nixon Wa5.4rner Commc?ns Inc U.S Phillips Motors F.3d 9th Cir Prescient Acquisition Grp Inc MJ Publ?g Trust Supp 2d S.D.N.Y Rosado Bridgeport R5.7o.1man Catholic Diocesan Corp A.2d Conn S.E.C Oakford Corp No Civ WL S.D.N.Y Mar S.E.C TheStreet.Com F.3d 2d Cir Schiller C7.2ity of N.Y No Civ WL S.D.N.Y Sept Tradewinds Airlines Inc Soros No Civ WL S.D.N.Y July United States Amodeo Amodeo II-7 F.3d 2d Cir United States Bagley U.S von Bulow von Bulow F.2d 2d Cir Rules Statutes Civil Rights Law Fed Civ Case Document Filed Page of PRELIMINARY STATEMENT Virginia Roberts Giuffre?s opposition is a study7.7 in m7.7i-2.3sdirection it dism7.7isses Professor Dershowitz?s desire to clear his nam8e-6 as a vendetta and it p5.4o.4sits that are irre9.7levant Far from7.9 requiring a web9.1 of circum7.9s.3tantial inf8.1e-1.1rences Pl Br at the Requested Docum7.8e-1.2nts show that Professor Dershowitz is entitled to make these facts public Ms Giuffre has waived any privacy in accu5.9satio5.9ns by selling5.9 her to the pres5.3s.2 an6.1d soliciting public atten5tion for her accu5sations agains5.2t-.2 Professor Dershowitz an5d others Her jealous guarding of the Requested Docum7.7e-1.3nts is not m7.7o.9tivated by privacy interest she possesses in their contents?she articulates none?but rather by a desire to avoid a full airing and robust discussion of the actual facts Ms Giuffre wishes to cherry5.8-pick level and false accusations against Professor Dershowitz in court filings an11d in interv5.5iews and continue to use the powers of this Court to protect her from7.8 6.6contrary evidence being public That is no6.1t just unfair it is also un6.1co6.1nstitu5.9tion5.9al As the Seco5.9nd Circuit long recognized litigants can6not file docu6m7.8ents in court to s5.1eek a litig5.9ation adv5.9a-1.3ntage while Case Document Filed Page of sim8.4u.8ltaneously shielding5.8 those docu5.8m8.4ents from8.4 public view The courts are presum8.4p.4tively public and the public has a right to7 monitor the judicial process?particularly as concerns Ms Giuffre?s accusations which her ow7.9n atto5.5rneys have argued in opposing5.5 restrictions on public access to co5.7urt filings detailing th9.1em are the of s5.1tro5.7ng curren5.7t-1.7 media in5.7terest.5.7 Nor does the fact that Professor Dershowitz is not a news agency negate his access rights The First Am7.8endment generally grants the press no right to infor-6.8m7.8ation about-5.6 a trial superior to that of the general public Nixon Warner Commc?ns Inc U.S In their efforts to assert that it was proper to publicly5.6 accuse Prof8.6essor Dershowitz of raping children Ms G7.7i-2.1uffre?s law7.7yers unwittingly reveal just how baseless these accusations really are The Reply Declaration of Alan Dershowitz con5.3f3.3ronts and d5.3i-2.1sproves Ms Giuffre?s allegations point by point But now that those accusations have been public and in court papers again and again?Pro5.2fessor Dershowitz cannot be forced to respond with one rhetorical hand tied behind his back m7.9o.3tion should be granted ARGUMENT PUBLIC HAS A RIGHT TO ACC-7.8ESS THE REQUESTED DO-7.9CUMENTS Requested Documents Are Judicial Documents to Which a Strong Presumption of Access Applies Ms Giuffre?s ignores that courts are split as to whether 7.6discovery related m7.7otions and their associated exhibits should be considered judicial documents Rosado Bridgeport Roman Catholic Diocesan Corp A.2d Conn Compare e.g Mokhiber Davis A.2d D.C holding that discovery m7.9o.3tions fall within the presum7.9p-.3tion of access to judicial docum8.2ents p6.4recisely becau5.6se discovery5.6 is so im8.2portant in trial p5.6r-1.4actice with e.g L6.8e-1ucadia Inc Applied Extrusion Inc F.2d 3d Cir disag5.7r-.2eeing5.7 with Mokh5.6i-.1ber but noting valid reasons why one could conclude that the common law presumptive right access to p5.5r-1.5etrial m8.1o.5tions is equally5.5 applicable to discovery motions Case Document Filed Page of The Second Circuit has not weighed in as Ms Giuffre acknowledges But she is wrong to assert that the Second Circuit will follow those courts that have adopted a catego5.6r-1.4ical ru5.6le against treating discovery m8o.4tion papers as judicial docum8ents Several of those courts have reached such a rule by rely5.6ing legal that the Second Circuit has roundly rejected For exam8ple som8e-1 Circuits hold that filings are only judicial docum8ents when they are relied upon by a court in determ8i-.2ning the m8erits of a suit or a litigant?s substantive rights or that confidential docum8ents filed in connectio6.9n with non-dispositive m8o.4tions are categorically beyond the reach of the presum8p0tion of access See e.g Ph5.4illips Motors F.3d 9th Cir Chicago Tribune Co Bridgestone/Firestone Inc F.3d 11th Cir Anderson Cryovac Inc F.2d 1st Cir But the Second Circuit has rejected these cramped constructions of the public?s rights See Newsday LLC Cnty of Nassau F.3d we have held that the First Am8endm8ent-7 right applies am8ong ot-7her things to pretrial m8o.4tions and written docum8ents subm8.2itted connection with them8.2 Lugosch Pyramid Co of Onondaga F.3d 2d Cir rejecting the suggestion that different types of docum7.8ents receive different weights of presum7.8p-.2tion based on the extent to which they were relied upon in resolving the m8.6o1tion United States Amodeo Amodeo F.3d 2d Cir noting that som8e-1 presumption of access exists with respect to any docum8.2ent which is presented to the court to invoke its powers or 5.1affect its decisions em7.7phasis added The Second Circuit generally construes judicial docum7.7ents more broadly to include docum7.8ents that are filed with the court that reasonably be relied upon in support of any part of the court?s adjudicatory function Rosado A.2d at em7.7phasis added describing the Second Circuit?s approach as consistent with Mokhiber This explains the nearly uniform8 consensus am8ong the district courts boun6.2d by its decisions in applying the presum8p.3tion Case Document Filed Page of of access to discovery m8.2o.6tion papers5 See e.g Alexander Interactive Inc Adorama Inc No Civ at S.D.N.Y Sept In re Gushlak No MC WL at E.D.N.Y July Gucci Am In5.4c Guess?,5.4 Inc No Civ at S.D.N.Y Apr In re Omnicom Grp Inc Secs Litig No Civ at S.D.N.Y Oct Schiller City of N.Y No Civ at S.D.N.Y Sept S.E.C Oakford Corp No Civ at S.D.N.Y Mar But other than inviting the Court to reject th8.8ese outlier opinions out of hand Pl Br at Ms Giuffre attem8.7pts no rejo6.1inder to the reasoning of Mokhiber and its progeny that modern discovery motions are core judicial processes that m7.9ay prove decisive to the outcom7.9e-1.1 of particular disputes and therefore must be open to public monitoring Mokhiber A.2d at observ5.3i-2.1ng that th5.3e availability of mandatory d5.3i-2.1scovery has g5.3r-1.7eatly affected the way in which our courts do justice This Court should adopt this persuasive rationale B.-2084.6Professor Motives Are Proper and Are Irrelevant Anyw7.8ay Ms Giuffre?s repeated attem7.9pts to cast Professor Dershowitz?s m7.9o.3tion as part of a vendetta against are as iron5.3ic as they are false Ms Giuffre publicly and falsely5.3 accused Professor Dershowitz sex crim8.2es then spent years attem8.1pting to profit from8.1 those allegations and dissem7.8i-2.2nate them7.8 widely as possible She now seeks to hijack this Court?s Article I powers to ham8.2s0tring Professor Dersh5.6o.6witz?s ab5.6ility to m8.2eet th5.6ose accusations in the public fora in which she has intentionally and repeatedly them Her newfound concerns about a m8edia war were nowhere in ev5.4iden5.4ce when she sold her story to the for six figures in taped an interview7.7 with ABC News and sm7.9eared Professor Dershowitz through surrogates even after lawyers adm8.2itted it was a to accus5e-.8 him8.2 of raping young girls.5.6 Case Document Filed Page of In any event the Second Circuit has expressly held that the otive of the person seeking disclosu5.8 re judicial cum8.6 ents is 223irrelevan6 to defining the weight acco6 rded to the presum7.9 ption of access Amodeo II F.3d at The rights at issue are those of the public at large and6 the law is clear th6 at acce5.8 ss ust be granted on that basis alone MS GIUFFRE HAS ARTICULATED BASIS FOR CONTINUED SECRECY Ms Giuffre 2s feeble attempts to conjure justifications for continuin to seal the Requested Docum7.8 nts do not withst-10 and scrutiny See Atmospherics Ltd Hansen A.D.3d 2d Dep 2t essential p5 erequisite to legal protection against the m8 sappropria11.1 tion of a trade secret is the elem7.9 ent of secrecy are precisely the kind of 223broad allegations of harm6.9 unsubstantiated by ecific exam7.6 ples or articulated reasoning at cannot satisfy the high standard for sealing judicial docum8.1 nts See Lytle JPMorgan Chase Supp 2d S.D.N.Y Even if Ms Giuffre did at would not outweigh Professor Dershowitz 2s interest in defending his reputation See Prescient Acquisition Grp Inc MJ Publ 2g Trust Supp 2d S.D.N.Y rejecting 223the notion that a generalized The Second rcuit hel7.5 in A7 ode8 II t9 at tive conside7 ations6.4 be7 st we ighe6.5 as part of asse6.6 rtion by pers6.5 on or firm12.1 of a ght of pri9.1 vacy sed on an ticip-4.2 ated jury as a resu-4.2 lt of disclosure as fact8.9 or goi8.9 ng to the wei8.1 ght of pres5.5 tion of access F.3d at Ms uffre6.6 no right of privacy over acc6.3 usations of repugna6.3 nt crim11.3 inal conduct has5.6 spe6.3 yea6.3 levying ugh urts and the dia The6.9 Sec6.9 nd rcuit 2s cautioni8.9 ng that8.9 sonal vendettas nee6.9 not aide6.9 id at efore6.6 has5.9 no pplication Case Document Filed Page of concern of adverse publicity con5.1 cern5.1 ng a public figure is a ufficiently com7.9 pelling reason that outweighs the presum7.8 ption of acces5.2 Telling)6 Ms Giuffre does not even attem7.8 pt to exp6 ain how Moreover even if the Requested Docum7.8 nts could be considered private in another context Ms Giuffre long ago waived any privacy interest in their conte She has de public accusations of sexual sconduct ainst Professor rshowitz and oth5 rs repeatedly in lawsuits and in paid edia interv5.9 iews see Dershowitz Decl and clearly has no interest in keeping those allegations Indeed Ms ffre does not dispute that her counsel deliberately filed her accusations against Professor Dersh5.5 owitz publicly in th5 CVRA Action Accordingly5 223any countervailing privacy interest of Ms Giuffre cannot defeat the stron presum7.6 ption of public disclosu5.7 re ere aterial she seeks to seal is already in the public dom8.2 ain JetBlue Airways Corp Helferich Patent Licensing Supp 2d E.D.N.Y EVEN IF THE REQUESTED ENTS ARE NOT PRESUMPTIVELY PUBLI-5.8 THERE IS NO BASIS A PRO-8 TECTIVE ORDER The Presumption Against Modification of a Protective Order Does Not Appl Ms Giuffre stakes her o6 pposition to the odification of the otective Order on a leg6 al rule that plainly does not apply The Second Circuit 2s presum7.8 tion against odification of a protective order applies where an6 reliance o6 n1 the Order is reasonab6 S.E.C TheStreet.Com F.3d 2d Cir here a litigant or deponent could not reasonably have relied on the continuation of a protective order a court may properly perm7.7 it modification of the order But Ms Giuffre never addresses the actor)5.4 courts in the Second Circuit have recognized as bearing on the reasonableness of reliance the scope the protective order the language of the order itself the leve)5.3 of inquiry the court undertook Case Document Filed Page before granting the order and nature of reliance on the order In EPDM Antitrus5t Litig Conn All four factors weigh against Ms Giuffre First she cannot dispute that the Protective Order grants sw7.6eeping protection to if not all discovery m7.9a-1.1terial produced in this litigation even discovery m7.8a-4.9terial that a party would have been required to disclose in the ab5.4sen5.4ce of a protective Id at The Protective defines the scope of its confidentiality protections circularly to include inform8.3ation that is con5.7f3.7idential effectively imposing no lim8.2it on the secrecy the p5.6a-.7rties can unilaterally m7.9a-1.1ndate without particularized judicial scrutiny See Dershowitz Decl It is therefore precisely the kind of or-7.6der that courts routinely modify In re EPDM F.R.D at Although such blanket protective orders be useful in expediting the flow of pretrial discovery m8a-1terials they are by nature overinclus4.8i-2ve and are therefore p5.4e4.1culiarly sub5.4j3ect to later m8.2odifi-6.8cation Stipulated orders are even less resistan5.4t to a reasonable request for modification5.7..7 in5.7t-1.7ernal q5.7uotation and citation om8.3itted Fournier Erickson Supp 2d S.D.N.Y granting m7.8o-4.8dification of protective order where stipulated order allow7.7e-1.1d for unilateral designation of an exhi5.5bit as protected m7.9a-1.1terial and it did not list specific docum8.2ents or delineate the kinds of 4.7docum8.1ents contem8.1plated for protection Second the Protective expressly contem12.5plates challenges to confidentiality designations and judicial m7.8odifications to the scope of its protections See Dershowitz Decl Ex These provisions it difficult to see how Ms Giuffre-6.3 can reasonably argue that she produced docum7.9ents in reliance on the fact that the docum7.9ents would always be kept secret Lugosch F.3d at the confidentiality order specifically contem7.8plates that relief from8.3 the provisions of the order be sought at any tim8.3e accord Allen City of N.Y Supp 2d S.D.N.Y In re EDPM F.R.D at Case Document Filed Page of Third this Court has never de a particularized finding that Requested Docum7.7 nts specifically rit judicially-enforced confidentiality Under such circum7.5 tances cannot be presum7.8 ed that every piece of discovery filed under the Order is actually orthy of such a high level of protection In re EPDM F.R.D at accord Fournier Supp 2d at Ms Giuffre twists this uncontroversial observation plying that Professor Dershowitz has som7.8 how impugned the Court 2s integrity or competence merely by pointing ut the obvious fact that the Court has not reviewed every docum7.9 en designated confidential nder the Pro5.6 ective Order to determ7.8 ine whether good cause has been shown While blanket protective orders can help stream7.9 line discovery In re EPDM F.R.D at the lack of particularized judicial scrutiny doo5.9 Ms Giuffre 2s claim8.7 of reasonable reliance Fournier Supp 2d at Finally the nature of Ms Giuffre 2s claim8.5 ed reliance weighs heavily against applying the presum7.8 ption against odification Ms Giuffre 2s only argum7.8 ents about her reasonable reliance on the Protective Order concern discovery she has produced not the Requested Docum7.8 nts Pl Br at discussing But reason5.9 able reliance is determ7.9 ined on a docum7.9 t-by-docum7.9 ent basis See e.g Lown Salvation Army Inc No Civ at S.D.N.Y Oct Ms Giuffre has never presen6.1 ted any sem7.7 lance of a justification for the Court aintain the secrecy of and whose contents she has selectively disclosed already in num8 erous m8 dia appearances over the course of several years let Ms Giuffre plainly did not produce much less create the Requested Doc nts in reliance on the Protectiv4.9 Order 223Where the rties have not given up any rights and indeed would have been compelled to p6 odu6 ce the d6 sco6 v1 ery aterials even in th6 absence of9 a protective order the presum7.8 ption against odification is not as strong In re EPDM Case Document Filed Page F.R.D at Lugosch F.3d at That is clearly the case here where the docum7.7ents in question are essentially See e.g Cohen Cohen No Civ at S.D.N.Y J-5.6une discussing discoverability of a plaintiff?s own statem7.6ents concerning the subject of the lawsuit No good cause exists for the issuance of a Court Order protecting Ms Giuffre?s she has selectively in the and to the bidd5.8er for years?fro5.8m causing annoyance em7.7barrassment oppression or undue burden or expense Fed Civ If the Presumption Applied Extraordinary Circumstances Exist to Justify Modification7.2 Even if Ms Giuffre had relied reaso5n0ably on the Protective Order which she did not it would still be subject to modification As an initial m8.2atter th5.4e overbread5.4th of a Protective Order itse5.9lf am7.7ounts to the type of extraordinary circ5.1u.1m7.9s.3tances necessary to justify m7.9odification In re Agent Or5.2ange Prod Liab Litig F.2d 2d Cir accord Tradewinds Airlines Inc Soros No Civ WL at S.D.N.Y July collecting authorities More im)7.6portantly Professor Dershow7.4itz?s need to defend himself against Ms Giuffre?s repeated false public accu5.1sations that he is a ch5.1ild rapist is an extraordin6a-.2ry circum7.8s.2tance that sh6ould be eno6ugh to justify m8odifying the Protective Order as concerns Although Ms Giuffre dism7.9isses the Requested Docum7.6e-1.4nts as irrelevant they indisputably5.1 The6.9 fact the Em10.9ails involve co5.6mm11unications 6with a7 re7.4porter neithe7.4r-1.4 6i8.4m16.2plicates any 6pri7.7v-3.1ilege nor justifies confidentiality 6protections 6The Em10.8ails are in Ms Gi7.8uf8.2fre possessi8.1on and 6were produced 6by Ms 6Giuffre?not a j-5ournalist?in discovery New York?s shiel7d 6law 6Civil 6Ri ghts Law 6only professional 6j-5o2.2urnalists and news6.6casters,?6.2 6and protects inform11.2ation 6?is not obtaina6.2b-3.3le from10.8 any al7.8ternative 6fact that Ms Giuffre is the6.8 s6.2o-3urce 6of the thus de6.8fe6.8ats any claim10.8 5.9privilege6 5.9Si8milarly the qualified federal 5.9journalist?s pri8.8vilege ca6.8nnot invoke6.9d 6by non-journal8.1i2.1sts and is ore 6not ba6.8sis for 6Giuffre to 6resist disc6.5losure of own statem10.6ents to a journalist or a 6journalist?s state-6.4m10.6e.7nts to 6her Bulo-6.1w 2d Cir In Gi8.4uffre6.4 ha6.4s alr Requeste-4d-3.8 6Do in disc6.3ove6.4ry to he6.4r adversary so any priv ilege is waived Case Document Filed Page of Just as a prosecuto5.9 would be bound to disclose such nited States Bagley U.S Professor Dershowitz should able to use them7.8 to defend against ccusations that h5 comm7.8 itted heinous crim7.8 es Ms Giuffre 2s filings here continue the public smear cam7.6 paign against Professor Dershowitz that she and her lawyers have affirm7.7 tively opted to prosecute in the dia and on public court dockets They seek the continued freedom7.7 to make their case against Professor Dershowitz in public by selectivel-10.1 disclosing Ms Giuffre 2s statem7.7 ents and accusations while co-opting this Court 2s powers under Rule to handicap Professor Der showitz from Alan Dersho5.6 witz never et Virginia Giuffre until after accused him8.4 of raping her repeatedly when she was a child chose to bring this lawsuit subjecting herself to the sam8 Rule req5.7 irem8.5 ents all litigan5.7 ts face Discovery has now showed that years before she ever accused Pro5.9 essor Dersh5.9 witz Ms Giuffre It has also revealed that Prohibiting Professor Dershowitz from8.3 revealing these exculpatory facts to the public even as accu5.2 sations of his involvem8 nt in repugnant crim7.6 inal acts con5.8 tinue to be republished in book after book and interview after interview ould be a perversion of the discovery rules The Court should not countenance such a disgraceful mi suse of the courts Ms Giuffre5.8 not denie5.8 that accusations against were leaked to the press6.1 Case Document Filed Page CONCLUSION For the foregoing reasons Professor Dershowitz respectfully requests th5.4at the Court grant his m8.1o.5tion for perm8.1issive intervention and unseal the Requested Docum8.1e-.9nts or in the alternative modify the Protective O8r-1.4der to perm8.2it their dissem8.2i-1.8nation Dated 85Septem8.1ber York New York-5.6 EMERY CE-4.6LLI BRINCKERHOFF ABADY LLP Andrew Celli David A Lebowitz 2750Fifth 2750Avenue th Floor New York New York Attorneys for Proposed Intervenor Alan Dershowitz Case Document Filed Page of a I a i i i 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