Case 1:15-cv-07433-LAP w Document 1060 Filed 06/18/20 Todd&Weld LLP Page 1 of 2 Howard M. E-mail: [email protected] June 18, 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. Maxwell. Case No.: 15-cv-07433-LAP Dear Judge Preska: Professor Alan Dershowitz ("Dershowitz") writes in brief reply to Ghislaine Maxwell's letter submitted yesterday. ECF No. 1059. Maxwell's position is the height of impracticality. The evidence Professor Dershowitz seeks from v. Maxwell is clearly discoverable given the overlapping allegations in the cases at issue, and she does not and cannot argue otherwise. Indeed, Maxwell ignores that the , whose materials sought are in the custody, possession or control of Plaintiff position is that she will need relief in order to be able to produce any materials the Court deems to be relevant to her lawsuit with Dershowitz. Maxwell likewise ignores that at least until the Court rules otherwise upon a motion related to specific materials, Dershowitz will comply with the existing protective order. Instead, Maxwell apparently seeks to force Dershowitz and this Court to litigate piecemeal each and every individual subpoena for materials from each and every witness in the Maxwell case from whom testimony and documents is sought. Maxwell seeks to force this path while making no showin whatsoever that the discovery materials Dershowitz are (i) not fairly in hands and discoverable, or (ii) why they would seeks from not be discoverable from Maxwell herself. Maxwell incorrectly contends that there have been three unsuccessful prior attempts made by non-parties to gain access to documents in Maxwell. ECF No. 1059 at 1-2. She characterizes each of these attempts as failed and then states that this Court's decisions somehow are the law of the case. Yet, the very standard she cites in her response provides an exception that clearly applies here. Id. at 2. As