Case 1:15-cv-07433-LAP BSF Document 1003 Filed 11/01/19 Page 1 of 1 BOIES SCHILLER FLEXNER Telephone: (954) 356-001I Email: [email protected] November 1, 2019 VIA ECF The Honorable Judge Loretta A. Preska District Court Judge United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 v. Maxwell, Re: Case no. 15-cv-7433-LAP Dear Judge Preska: Plaintiff hereby responds to the Court's October 30 2019, order, Dkt. 1000, concerning Alan Dershowitz's request fib-Answer discovery in v. Dershowitz, supports the unsealing of this case's docket. 19 Civ. 3377. As set forth in her earlier filings, See Dkt. 995 at 7 ("[A]ll of the documents in question are judicial documents, and accordingly the entire record should be unsealed, subject to redactions similar to what the Second Circuit applied."). objects, however, to the selective unsealing that would occur if only one party, Dershowitz, is allowed to publish specific documents for use in counterclaims he intends to file against her. See Dkt. 1001 (Dershowitz requesting "unsealing of the limited material Mr. Dershowitz seeks"). To avoid the prejudice of allowing only one party to use the currently-sealed materials, contends that the documents in question should simply be handled in the same fashion as all others. See Dkt. 999 at 2. If the Court grants Dershowitz's request for pre-Answer discovery, expects that she will also be allowed to identify and publish sealed materials in response to Dershowitz's forthcoming counterclaims. Sincerely, /s/ Sigrid McCawley Sigrid S. McCawley, Esq. cc: Counsel of Record (via ECF) BOIES SCHILLER FLEXNER LLP 401 East Los Olos Boulevard. Suite 1200. Fort Lauderdale. FL 33301 1 (t) 95d 356 0011 1 (f) 95d 356 00221 www.bstlIp.corn EFTA02781414