gov.uscourts.nysd.447706.1296.17.pdf

EXHIBIT A RICHARD D. EMERY EMERY CELLI BRINCKERHOFF & ABADY LLP TELEPHONE ANDREW G. CELLI, JR. (212) 763-5000 ATTORNEYS AT LAW MATTHEW D. BRINCKERHOFF 600 FIFTH AVENUE AT ROCKEFELLER CENTER FACSIMILE JONATHAN S. ABADY 10TH FLOOR (212) 763-5001 EARL S. WARD NEW YORK, NEW YORK 10020 WEB ADDRESS ILANN M. MAAZEL www.ecbalaw.com HAL R. LIEBERMAN DANIEL J. KORNSTEIN CHARLES J. OGLETREE, JR. O. ANDREW F. WILSON DIANE L. HOUK ELIZABETH S. SAYLOR DEBRA L. GREENBERGER ZOE SALZMAN SAM SHAPIRO ALISON FRICK DAVID LEBOWITZ HAYLEY HOROWITZ DOUGLAS E. LIEB ALANNA KAUFMAN JESSICA CLARKE EMMA L. FREEMAN FILED UNDER SEAL June 21, 2017 By ECF Honorable Robert W. Sweet United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Giuffre v. Maxwell, No. 15 Civ. 7433 (RWS) Dear Judge Sweet: This firm represents Intervenor Professor Alan M. Dershowitz, and we write in anticipation of the parties’ forthcoming motion practice concerning the confidentiality of the Sarah Ransome deposition. 1 Intervenor requests that, if the Court allows Plaintiff Virginia Giuffre to remove the confidentiality designation concerning the Ransome deposition—an action that would require modification of the Protective Order in this case —it also simultaneously remove the confidentiality designation from several related emails and attachments that the parties previously designated confidential (RANSOME_000273-557) (“the Emails”). The Emails will demonstrate that Ms. Ransome’s inflammatory, salacious, and defamatory testimony concerning the Intervenor and others is false and that the deponent is not credible. Absent this relief, Ms. Ransome’s unrebutted testimony will gravely prejudice Intervenor by publishing deliberate lies calculated to harm his reputation. Counsel for Ms. Giuffre has not indicated whether she consents to removing the confidentiality designation from the Emails; and counsel has indicated that Ms. Giuffre “is not sure” whether she will seek to remove the confidentiality designation from the Ransome deposition, notwithstanding her prior letter requesting that relief 1 Intervenor Dershowitz respectfully submits that issues concerning the confidentiality of particular materials under the protective order are not mooted by the settlement of the underlying action. See Gambale v. Deutsche Bank AG, 377 F.3d 133, 140-41 (2d Cir. 2004). Exhibit 1 Exhibit 2 Exhibit 3 Exhibit 4 Exhibit 5 Exhibit 6