Case 1:15-cv-07433-LAP BOIES. A-D Document 1218-51 SCHILLER O:)-EVARD • 0 & Filed 07/15/21 FLEXNER Page 1 of 3 LLP ,..r)LRDALE. FL 33301 2211 • PH 954 356 0011 • FAX 954 356.0022 Sigrid S. McCawley, Esq. E-mail: [email protected] September 28, 2016 VIA CM/ECF Honorable Judge Robert W. Sweet District Court Judge United States District Court 500 Pearl Street New York, NY 10007 Re: v. Maxwell, Case No.: 15-cv-07433-RWS Dear Judge Sweet: We write to respond briefly in opposition to Proposed Intervenor Alan M. Dershowitz's letter motion of September 26, 2016, for leave to publicly file a less-redacted version of Dershowitz's Reply Declaration. The motion is untimely and unjustified. However, the Court need not even reach those considerations as Dershowitz is not a party and has no standing to make this motion. Dershowitz's letter tacitly admits the same by wholly failing to address the standing defects that preclude him from seeking this relief. If we understand the letter motion correctly, it appears to argue that the Professor Cassell's declaration, filed August 29, 2016, was too heavily redacted. Dershowitz gives no explanation for waiting four weeks for raising this issue. Importantly, under the Protective Order that exists in this case, any challenges to a redaction must be raised by written notice to the party designating the disputed information, andnot brought to the court before ten business days after the notice is received. Dershowitz is bound by the terms of the Protective Order through his receipt of confidential materials from the Defendant.' In bringing this letter motion, Dershowitz violates those terms by failing to provide written notice to the designating party, and prematurely brings this motion before the Court in direct contravention of this Court's Protective Order. This premature filing, in contravention of this Court's Order, is yet another reason to deny this motion. The Protective Order states: "Prior to disclosing any CONFIDENTIA