Case 1:15-cv-07433-LAP Document 1059 Filed 06/17/20 Page 1 of 3 Haddon, II A I/ I/ UN N and I l. P.0 Ty Gee 150 Eost 10th Avenue Denver. Colorado 80203 PH 303.831.7364 rx 303.832.2628 www.hmflaw.com tgeeehmtlaw.com June 17, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Mr. Dershowitz's Request for Discovery Subject to Protective Order Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: Defendant Alan Dershowitz in v. Dershowitz, No. 19-cv-3377 (LAP) filed a request in that case and this one to request a conference. He intends as a non-party to move in this case to modify the Protective Order (Doc.62) so that he has access to "all filings and discovery materials, including third-party discovery." Doc.1058-1, at [1]. There is no basis for such a modification. Mr. Dershowitz's request is brought on plowed ground. In October 2017 third parties sued by an alleged Epstein victim moved to modify the Protective Order to permit them to "use all evidence" produced by a non-party witness in this case. Doc.924 (filed under seal Oct. 5, 2017). In a sealed opinion this Court denied the motion. It ruled that the Protective Order did not extend beyond the completion of discovery or beyond the termination of the case, which the Court determined had occurred. Sealed Op. 7 (Nov. 14, 2017). Accordingly, the Court concluded, the documents the third parties sought were not subject to the Protective Order. Instead they were in the actual or constructive possession of the parties, since the Protective Order required that upon case termination all documents would be returned to the party designating the documents as confidential. See id. In March 2017 intervenor Cernovich moved for access to materials in this case, including documents produced in discovery. Doc.551; Doc.892, at 4, 9. The Court construed the motion as one to modify the Protective Order, and denied it. Doc.892, at 4-10. It