Case 1:19-cv-10474-NRB Document 10 Filed 12/11/19 Page 1 of 3 BSF1 BOIES SCHILLER FLEXNER Telephone: (212) 446-2300 Email: iischillerabsfilv.com December 11, 2019 VIA ECF The Honorable Naomi Reice Buchwald District Court Judge United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: v. Indyke a al., case Nr,. 19-cv-10474 Dear Judge Buchwald, Plaintiff writes in response to non-party Alan Dershowitz's request for a pre-motion conference to seek permission to file a motion for limited intervention, to strike paragraph 39 of Plaintiff's complaint, and for sanctions. Dkt. 9. Paragraph 39 of Maria's complaint states that "Din her position at the front door" of Epstein's mansion, "she observed that [Ghislaine] Maxwell was regularly bringing school-aged girls to the mansion," and that Maria "observed Alan Dershowitz, a lawyer, on a number of occasions, and observed that he would go upstairs at the same time the young girls were there." These allegations are directly relevant to establishing Maria's claims, and bolster the plausibility of the complaint's allegations as to the existence of a sex-trafficking conspiracy, the abuse Maria suffered, and how Epstein and his co-conspirators were able to coerce her to remain silent. The allegations serve a legitimate purpose, and are in no way "redundant, immaterial, impertinent, or scandalous." Fed. R. Civ. P. 12(f). For the following reasons, the Court should deny Dershowitz's request for a conference and his proposed motions in their entirety. I. Dershowitz Is Not Entitled to Intervene in This Matter. Rule 24(a)(2) of the Federal Rules of Civil Procedure governs intervention as of right, and provides that "the court must permit anyone to intervene who ... claims an interest relating to the property or transaction that is the subject of the action, and is so situated that disposing of the action may as a practical matter impair or impede the movant's ability to protect its interest,