gov.uscourts.nysd.447706.1003.0.pdf

Case 1:15-cv-07433-LAP Document 1003 Filed 11/01/19 Page 1 of 1 Telephone: (954) 356-0011 Email: [email protected] November 1, 2019 VIA ECF The Honorable Judge Loretta A. Preska District Court Judge United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Giuffre v. Maxwell, Case no. 15-cv-7433-LAP Dear Judge Preska: Plaintiff Virginia Giuffre hereby responds to the Court’s October 30, 2019, order, Dkt. 1000, concerning Alan Dershowitz’s request for pre-Answer discovery in Giuffre v. Dershowitz, 19 Civ. 3377. As set forth in her earlier filings, Giuffre supports the unsealing of this case’s docket. See Dkt. 995 at 7 (“[A]ll of the documents in question are judicial documents, and accordingly the entire record should be unsealed, subject to redactions similar to what the Second Circuit applied.”). Giuffre objects, however, to the selective unsealing that would occur if only one party, Dershowitz, is allowed to publish specific documents for use in counterclaims he intends to file against her. See Dkt. 1001 (Dershowitz requesting “unsealing of the limited material Mr. Dershowitz seeks”). To avoid the prejudice of allowing only one party to use the currently-sealed materials, Giuffre contends that the documents in question should simply be handled in the same fashion as all others. See Dkt. 999 at 2. If the Court grants Dershowitz’s request for pre-Answer discovery, Giuffre expects that she will also be allowed to identify and publish sealed materials in response to Dershowitz’s forthcoming counterclaims. Sincerely, /s/ Sigrid McCawley Sigrid S. McCawley, Esq. cc: Counsel of Record (via ECF)