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ID LEBOWITZ DOUGLAS E. LIEB ALANNA KAUFMAN EMMA L. FREEMAN DAVID BERMAN ASHOK CHANDRAN DANIEL TRUMAN This firm represents Intervenor Professor Alan M. Dershowitz, and we write to alert the Court to certain troubling developments concerning the treatment of materials subject to this Court's orders, and to see
y leaked to members of the press. We believe that these materials, which repeat provably-false and defamatory alleSof sexual misconduct against Mr. Dershowitz, were leaked by persons associated with Roberts ("Ms. Roberts"), the plaintiff in the above-captioned matter. Once again, Mr. Dershowitz — who ha
TRUMAN This firm represents Intervenor Professor Alan M. Dershowitz, and we write to alert the Court t
for over two years. But, because this Court has thrice denied applications for such disclosure (once when made by Mr. Dershowitz; once when made by Michael Cemovich; and a third time when made by the Miami Herald), and because these issues are currently on appeal in the Second Circuit, Mr. Dershowitz asks that
led under seal by order of Judge unsealed and made public. (15-cv-7433, Dkt. Nos. 362, 550, 935.) Harvard Law professor and criminal defense lawyer Alan Dershowitz, whom publicly alleged of perpetrating sex crimes alongside Epstein, moved to unseal a limited portion of the record in order to clear his name. (
d Law professor and criminal defense lawyer Alan Dershowitz, whom publicly alleged of perpetrating sex crim
arvard Law professor and criminal defense lawyer Alan Dershowitz, whom publicly alleged of perpetratin
ein, moved to unseal a limited portion of the record in order to clear his name. (15-cv-7433, Dkt. No. 364 at 1.) Alt-right activist and provocateur Michael Cemovich also sought to unseal the papers filed as part of Maxwell's motion for summary judgment, arguing, "Cemovich Media cannot conduct its Forth [sic] Es
ndents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Me
Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Interveno
DER v. 20-2413 Ghislaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDERED that the United States shall submit an amicus letter brief, not to exceed
slaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDERED that the United States shall submit an amicus letter brief, not to exceed ten (10) double-s
udgment was redacted. (ECF No. 872.) In response to the sealing, two separate parties moved to intervene and to unseal selected filings. The first, Alan Dershowitz, himself implicated in the Epstein scandal, moved to intervene and to unseal three documents or in the alternative to modify the Protective Order (t
and to unseal three documents or in the alternative to modify the Protective Order (the "Dershowitz Motion"). (ECF No. 362.) The documents that Mr. Dershowitz targeted are currently unidentifiable because the Dershowitz Motion was partially redacted, and the order denying the motion to unseal was itself s
rvene and to unseal selected filings. The first, Alan Dershowitz, himself implicated in the Epstein sca
partially redacted, and the order denying the motion to unseal was itself sealed. The second individual, podcast host and investigative journalist Michael Cemovich, moved to intervene and unseal Defendant's Motion for Summary Judgment (the "Cemovich Motion"). (ECF No. 550.) The portion of the Cemovich motion se
Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Interveno
ndents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Me
DER v. 20-2413 Ghislaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDERED that the United States shall submit an amicus letter brief, not to exceed
slaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDERED that the United States shall submit an amicus letter brief, not to exceed ten (10) double-s
DER v. 20-2413 Ghislaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDERED that the United States shall submit an amicus letter brief, not to exceed
Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Interveno
ndents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Me
slaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDERED that the United States shall submit an amicus letter brief, not to exceed ten (10) double-s
enor Michael Cemovich: RANDAZZA LEGAL GROUP, PLLC, 100 Pearl Street, 14th Floor, Hartford, CT 06103, By: Jay M. Wolman, Esq. Counsel for Intervenor Alan Dershowitz: EMERY CELLI BRINCKERHOFF & ABADY, LLP, 600 Fifth Avenue, 10th Floor, New York, NY 10020, By: Andrew G. Celli, Jr., Esq. I This daytime business a
Page: EFTA00020552 →OREMAN, P.C., 150 East 10th Avenue, Denver, CO 80203, By: Laura A. Menninger, Esq., Jeffrey S. Pagliuca, Esq., Ty Gee, Esq. Counsel for Intervenor Michael Cemovich: RANDAZZA LEGAL GROUP, PLLC, 100 Pearl Street, 14th Floor, Hartford, CT 06103, By: Jay M. Wolman, Esq. Counsel for Intervenor Alan Dershowitz: EMER
Page: EFTA00020552 →g Order, ECF No. 348. One hundred sixty-seven documents were sealed pursuant to the Sealing Order. On August 11, 2016, Intervenor Alan Dershowitz ("Dershowitz" or "Intervenor Dershowitz") moved to unseal three documents: (1) portions of a Reply Brief submitted by Churcher in support of her motion to quash
Page: EFTA00020556 →20-2413 Ghislaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDERED that the United States shall submit an amicus letter brief, not to exceed
Page: EFTA00028060 →slaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. It is hereby ORDERED that the United States shall submit an amicus letter brief, not to exceed ten (10) double-s
Page: EFTA00028060 →Entities connected to both Alan Dershowitz and Michael Cemovich

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Donald Trump
PERSON
Woody Allen
PERSON
Virginia Giuffre
PERSON
Julie K. Brown
PERSON
David Boies
PERSON
Larry Page
PERSON
Southern District of New York
ORGANIZATION
Cynthia Nixon
PERSONSecond Circuit
ORGANIZATIONSharon Churcher
PERSONSweet
PERSONLoretta A. Preska
PERSON
The Miami Herald
ORGANIZATION
Nassau
LOCATION
Schiller
PERSON
Bernstein
PERSON
Foley Square
LOCATION