caesElslaforenti3i3altAP crawasteent909 Fileitt0.00119.9 Pacradeof Zf 2 KRIEGER & LEWIN up Telphonc:(212)390-9550 ArimAXIllimovu 500 Fifilt Avenue New VOA. NY 101 10 October 30, 2019 By ECF • r USDCSDNY The Honorable Loretta A. Preska United States District Judge Southern District of New York 500 Pearl Street, Room 2220 New York, NY 10007-1312 Re: DOCUMENT ELECTRONICALLY FILED DOC 0: DAM FILED:Jo - 3o - tei v. Maxwell, 15 Civ. 07433 (LAP) Dear Judge Preska: We write on behalf of a non-party, John Doe regarding the letter filed by Alan Dershowitz on October 24, 2019, in the case of v. Dershowitz, 19 Civ. 3377 (LAP). See 19 Civ. 3377 (LAP) Docket Entry ("DE") 71. By that letter, Dershowitz — the defendant in that case, and an intervenor seeking categorical unsealing of all sealed filings here — requests that this to "immediately produce" two Court order the plaintiff there (and here) documents that he styles as "pre-Answer discovery." Id. On the following day, October 25, 2019 this Court directed counsel in that case to confer regarding Dershowitz's request and, if disagrees with Dershowitz's request, to so inform the Court by November 4, 2019. See DE 72. The Court should not permit Dershowitz to engage in an end run around the unsealing process Your Honor is conducting in this matter. Dershowitz seeks the "immediate" production of two non-public documents, including partially sealed deposition taken in this case. DE 71. This request effectively proposes to by-pass the sealing-review process this Court has initiated here. And Dershowitz does not even attempt to address how his request can be aligned with the sealing-review process in this case. Nor does he articulate why pre-answer access to sealed documents — which he presumably intends to unilaterally unseal and use in potential counterclaims and his answer — would be necessary to satisfy notice-pleading requirements. gt geatio xitailord ki Mg awe Mai 92c hibt -14 _ 27a4 1 rei 4" 90 R1512/2( Nisi) 719 --