Case 1:15-cv-07433-LAP KRIEGER Document 1062 Filed 06/22/20 Page 1 of 7 & LEWIN LLP Telephone: (212) 390-9550 v.ww.KKIJIpkom SOO Filih Arcnue Na. York, NY 10110 June 22, 2020 By ECF The Honorable Loretta A. Preska United States District Judge Southern District ofNew York 500 Pearl Street, Room 2220 New York, NY 10007-1312 Re: v. Maxwell, 15 Civ. 7433 (LAP) ("Maxwell") Dear Judge Preska: We write on behalf of a non-party, John Doe, regarding the letter filed brai Dershowitz on June 12, 2020, in the above-referenced case ("Maxwell") and in v. Dershowitz, No. 19 Civ. 3377 (LAP) ("Dershowitz"). See Maxwell, DE 1058-1. By that letter, Dershowitz sets forth his intent to seek an order compelling Plaintiff "and others" to produce "all filings and discovery materials, including third-party discovery," from Maxwell, including documents governed by the Maxwell Protective Order and sealed materials (the "Sealed Documents") presently under review by this Court pursuant to the agreed-upon protocol. Id. This marks Dershowitz's second — or, by some measures, third — attempt to make an endrun around this Court's carefully constructed unsealing protocol. Just as the Court denied Dershowitz's prior attempts, it should deny this one.' A. This Court's Rejection of Dershowitz's Initial Attempts to Oppose or Circumvent the Protocol Earlier this year, after substantial input from and discussion with the parties, the Court finalized the protocol for the individualized review of the Sealed Documents that was mandated by the Second Circuit. Maxwell, DE 1044. Dershowitz, as an intervenor, opposed this protocol A decision on whether to grant Dershowitz's motion for leave to file his proposed motion to compel "and others" to produce discovery could have a substantial and realtime effect on the ongoing unsealing review pursuant to the Court's carefully crafted protocol. Accordingly, and notwithstanding our familiarity with the Court's Individual Practice 2(A), we have filed this let