Case 1:15-cv-07433-LAP Document 1002 Filed 11/01/19 Haddon, Page 1 of 2 and P.0 Ty Gee II A I) I) 0 N N ISO East 10th Avenue Denver, Colorado 80203 Pll 303.831.7364 FX 303.832.2628 wve.v.hmflaw.com Igeet/hmflaw.com November 1, 2019 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: October 30 Order (Doc.1000) Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: In a different case, v. Dershowitz, No. 19-cv-3377 (LAP) (S.D.N.Y.) defendant Mr. Dershowitz requested pre-answer discovery—"immediate[] produc[tion]" of sealed documents in the case at bar. Doc.71, No. 19-cv-3377. Non-party John Doe objected in the case at bar to the discovery. Doc.999. On behalf of defendant Ghislaine Maxwell, we submit this response to Mr. Doe's objection. We have read plaintiff's alleas of "defamation" in the v. Dershowitz lawsuit, which is v. Maxwell redux. It is plaintiff's familiar litigation template: Identify a prominent person with any ties to Jeffrey Epstein, go to the media, make false allegations that that person participated in Mr. Epstein's "sex trafficking ring," wait for the public denial, and then sue for "defamation." So we agree with Mr. Dershowitz that deposition testimony and related exhibits, are "relevant to [the Dershowitz] claim[s] or defense[s]," Fed. R. Civ. P. 26(b)(1). To the extent the Court agrees Mr. Dershowitz's request for pre-answer discovery should be granted, the Court may permit the discovery while preserving the parties' and non-parties' interests in the case at bar. and the media intervenors in the case at bar have taken the position that none EFTA02781412