Case 1:15-cv-07433-LAP w Document 1058-1 Filed 06/12/20 Todd&Weld LLP Page 1 of 3 Howard M. E-mail: [email protected] June 12, 2020 Via ECF Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007-1312 Re: v. Dershowitz. Case No.: 19-cv-03377-LAP and v. Maxwell, Case No.: 15-cv-07433-LAP Dear Judge Preska: I write pursuant to Rule 2.A. of Your Honor's Individual Practices. Defendant Alan Dershowitz ("Professor Dershowitz" or "Dershowitz") respectfully requests a pre-motion conference with Your Honor in the above matters to discuss his request that this Court compel Plaintiff ("Plaintiff") and others to produce to him all filings and discovery materials, including third-party discovery, from v. Maxwell, Civil Action No. 15-07433 ("Maxwell"),I As Your Honor is aware from our initial conference, the discovery in Maxwell overlaps substantially with the discovery in Plaintiffs suit against Professor Dershowitz, and its production will promote efficiency and avoid duplication in this case. Plaintiff does not dispute this but takes the position that the Protective Order in Maxwell prevents her from producing the requested materials. Likewise, third-party witnesses from whom Professor Dershowitz has sought discovery have already or are expected to raise similar objections. Professor Dershowitz has explained that he is prepared to abide by any applicable court order subject only to reserving the right to seek relief from the Court as to particular items if appropriate, a right which would exist in any event. Through this letter, Professor Dershowitz seeks leave to file a motion in both his case and in Maxwell allowing him access to all discovery materials and pleadings in Maxwell. Of course, if the Court prefers a different procedural route to accomplish what he requests, then Professor Dershowitz will follow the Court's directive. Professor Dershowitz will be brief with respect to the obvious. It