gov.uscourts.nysd.447706.1185.0_1.pdf

Case 1:15-cv-07433-LAP Document 1185 Filed 01/05/21 Page 1 of 1 Howard M. Cooper E-mail: [email protected] January 5, 2021 VIA ECF Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007-1312 Re: Giuffre v. Dershowitz, Case No.: 19-cv-03377-LAP Giuffre v. Maxwell, Case No.: 15-cv-07433-LAP Your Honor: Professor Dershowitz has reviewed the submission made by non-party John Doe, ECF No. 1182 in Giuffre v. Maxwell, in which Mr. Doe takes issue with the agreed-upon Protective Order entered by the Court as ECF No. 227 in Giuffre v. Dershowitz. Specifically, Mr. Doe asserts that the Protective Order permits the parties in Giuffre v. Dershowitz to file sealed material from Giuffre v. Maxwell to the public docket in Dershowitz without prior judicial approval. Professor Dershowitz reiterates and incorporates by reference his prior objections to John Doe’s repeated attempts to assert himself into these proceedings, particularly where it appears that Mr. Doe never provided any discovery in reliance on the Protective Order in Giuffre v. Maxwell and therefore has no rights under the same. See August 24, 2020 Letter from Ansari and Cooper in Giuffre v. Dershowitz, ECF No. 171. Regardless, Mr. Doe’s interpretation of the recently-entered Protective Order in Dershowitz is incorrect. The Court will recall that Ms. Giuffre has, for the sake of efficiency, re-produced in the Dershowitz case her document productions from the Maxwell case with whatever confidentiality designations were originally applied in the Maxwell case. Recognizing that some documents which Ms. Giuffre designated as confidential in Maxwell may not appropriately be designated as confidential in Dershowitz, the Protective Order provides a procedure whereby Ms. Giuffre will consider removing such inappropriate designations upon request. The Protective Order does not purport to confer authority on either party to publicly file any sealed documents from the Maxwell case without first seeking leave of Court. Mr. Doe’s concerns are thus without merit and the Court should deny his request as moot. Respectfully submitted, /s/ Howard M. Cooper Howard M. Cooper cc: All counsel of record, via ECF and email Todd & Weld LLP • Attorneys at Law • One Federal Street, Boston, MA 02110 • T: 617.720.2626 • F: 617.227.5777 • www.toddweld.com