Case 1:15-cv-07433-LAP Document 1001 Filed 10/30/19 Page 1 of 2 LAW OFFICES OF (dada ARTHUR L AIDALA MARIANNE E. BERTUNA HON. BARRY KAMINS MET.) JOHN S. EMMEN / Ofnetteneag E gragneta i 8118-13^. AVENUE BROOKLYN, NEW YORK I I 228 TEL: (718) 238-9898 546 FIFTH AVENUE DOMINICK GULLO MICHAEL T. JACCARINO IMRAN R ANSARI ANDREA M. ARRIGO NEW YORK, NY 10036 FAX: (718) 921-3292 TELEPHONE: (212) 4880011 OF COUNSEL . BARATTA CASSANDRA II A PETER W. KOLP WILLIAM R. SANTO PETER S.' AIIII FACSIMILE: (212) 7504297 WWWAIDALALAW.COM SENIOR COUNSEL LOUIS R. AIDALA allit BARATTA October 30, 2019 VIA ECF Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: IlMv. Dershowitz, Case No. 19-Civ-3377-LAP Response to Letter Filed by John Doe Dear Judge Preska, Defendant Alan Dershowitz (hereinafter "Mr. Dershowitz") respectfully writes the Court in response to the letter filed counsel to "John Doe" (hereinafter "Mr. Doe") today in MIE v. Marvell, Case No. 15-Civ-07433-LAP, [Dkt. No. 999] raising objection to Mr. Dersnvi 's request to engage in discrete pre-Answer discovery in the instant matter, to wit, requesting the unsealing of Plaintiff's testimony, along with corresponding exhibits, in the v. Maxwell case, and et al v. Dershowitz Case No.: CACE 15-000072 (Cir. Ct.W: ard Cnty., Fla.). By filing the instant lawsuit against Mr. Dershowitz, Plaintiff has "opened the door" and put at issue her prior statements, testimony, pleadings, filings, conduct and actions as they relate to Mr. Dershowitz and the allegations she has made against him. Perhaps most critical of this material, is the prior sworn testimony she has given in collateral yet clearly related matters. Plaintiff's deposition testimony, along with the corresponding exhibits, are necessary and material evidence that Mr. Dershowitz requires in order to answer the allegations made by the Plaintiff in her Complaint, and also filing his own Cou