Case 1:15-cv-07433-LAP Document 1106 TODD & WELD LLP One Federal Street 27th Floor Boston, 02110 (617) 720-2626 Filed 08/24/20 Page 1 of 6 AIDALA, BERTUNA & KAMINS, PC 546 Fifth Avenue, 6ih Floor New York, NY 10036 (212) 486-0011 August 24, 2020 VIA ECF The Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: v. Dershowitz, Case No 19-cv-3377-LAP v. Maxwell, Case No. 15-Civ-7433-LAP Dear Judge Preska: Defendant Alan Dershowitz ("Dershowitz") respectful/ writes the Court in response to the letter filed by John Doe ("Doe") on August 19 2020 v. Maxwell Dkt. No. 1105) in on to Dershowitz's request that Plaintiff ("=") produce to him in v. Dershowitz ("Dershowitz") certain confidential discovery materials and sealed filings from the v. Maxwell ("Maxwell") matter. "li Although the Court initially denied Dershowitz's request to modify the Maxwell Protective Order (Dkt. No. 144), after it came to light that counsel in Dershowitz possesses and has reviewed confidential and sealed materials from Maxwell, the Court subsequently directed the parties in Dershowitz to confer regarding "reasonable accommodation concerning Mr. v. Maxwell" so as Dershowitz's requests for various filings and discovery materials from to be "practical" and "avoid making this issue into a lengthy and expensive sideshow[.]" (Dkt. No. 152). The parties in Dershowitz have done just that and have presented a "reasonable" approach in which has no objection to producing certain enumerated categories from among the Maxwell confidential materials and sealed filings in her possession so long as the Court deems them relevant and grants her permission to do so. This proposal has been laid out in Dershowitz's and Joint Letter to the Court filed on July 29, 2020 (Dkt. No. 153). Accordingly, Dershowitz has requested that counsel be permitted to produce to Dershowitz all categories of documents listed on Appendix A of Defendant's July