Case 1:19-cv-03377-LAP Document 100 Filed 12/20/19 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. ALAN DERSHOWITZ, Defendant. ALAN DERSHOWITZ, Counterclaim Plaintiff, v. Counterclaim Defendant. Civil Action No. I :19-cv-3377 (LAP) PLAINTIFF'S MEMORANDUM OF LAW IN SUPPORT OF HER MOTION FOR LEAVE TO FILE AN AMENDED COMPLAINT Pursuant to Rule 15(a) of the Federal Rules of Civil Procedure, Plaintiff- respectfully requests leave of the Court to file the attached Amended Complaint. This motion should be granted for three reasons. First, since Plaintiff filed her complaint in April 2019, the revival provision of the New York Child Victims Act has gone into effect, reviving a battery claim against Defendant Alan Dershowitz that had previously been time barred. N.Y.C.P.L.R. § 214-g. Second, since Plaintiff filed her Complaint, Defendant has produced a copy of a recording that he represents captures a portion of a confidential telephonic settlement conference between EFTA00027039