EFTA01340455

LAW OFFICES OF cs417,4, ,W ag Ste424: fl ARTHLR L ADALA• WARVAIKE E LIERTUNK HON &AMY KAMINS MET) HON. JOIN IA LEvarm OCT) J044. S. ESPOSITO' NOVEL T JACCARINO IMRAN H. ANSARI DAM FAB, SA/40W ANDREA M ARMCO' LINO J DE MASI MICHAEL F OBENEOCTO' TAYLOR I/ FR ECM Ah• 'ALSO ACMR®IN 1CM JOSEY ••M.S0 ADMITTED II CCONECTEuT .ALSO ADMITTED°. TDAS 546 FIFTH MERLE NEW YOWL. NY 10036 TELEPHONE: FACSIMILE VOW/ AIDALN.AW June 16. 2022 VIA E-MAIL Office of the United States Attorney Southern District of New York One Saint Andrews Plaza New York, NY 10007 Attn: AUSAs Re: United States v. Maxwell Dear Counsel: 6116 13" AVENUE BROOKIN. NEW YORK 11226 TEL r718) 2)84898 MX' fa1-32/.2 OF COUNSEL JOSEPH A. BARATTA ANTOINETTE LANTOS VALUAA1 R. SANTO PETER S. THOMAS LAWRENCE SPASO.EVICH SENOR COUNSEL =AS R MONA JOSEPH P. BARATTA We are attorneys for Alan Dershowitz ("Professor Dershowitz") in the civil matter of v. Alan Dershowitz pending before Hon. Loretta Preska in the Southern District of New York. lack of credibility, and actual conduct in recruiting young girls for Jeffrey Epstein, are critical issues in the above-mentioned litigation. We write to notify you that gave approximately nine hours of deposition testimony across the span of two days on April 13th and 14th, 2022, in Washington, D.C. Her lawyers have designated the entire transcript to date as confidential under the applicable protective order. Our efforts to have the transcripts unsealed and made public have been denied by Judge Preska. Also denied was our request to provide the transcript to your office so that you could determine, on an informed basis, whether it would be appropriate or ethical for you to allow Ms. to give a victim impact statement during the sentencing phase of the Ghislaine Maxwell trial and therein vouch in that proceeding for her credibility. Both the Court, and ..ounsel, have made clear that they agree that we may notify you of the existence of the transcripts so that you can have the opportunity to review her testimony before she is allowed to provide a victim impact statement at the upcoming sentencing of Ghislaine Maxwell. We urge you, respectfully, to require her to produce it to you for your SDNY_GM_02775902 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00262542 EFTA01340455 review and careful consideration before permitting her to make a victim impact statement. In furtherance of this request, we enclose for your consideration a letter from Professor Bruce Green regarding the ethical considerations applicable to this matter. Please le ou have any questions or would like to discuss this matter further. We are copying counsel here to help facilitate your request for her transcripts. Yours, etc. Imran H. Ansari ( 44444444 Arthur L. Aidala \-Pemr(A-F)ciesiW Barry Kamins John M. Leventhal end: Bruce Green Letter cc: Todd & Weld. LLP Attorneys for Alan Dershowitz Howard M. Cooper Christian G. Kiely Kristine C. Oren Cooper & Kirk, PLLC Attorneys for [REDACTED] Charles J. Cooper Michael W. Kirk Nicole J. Moss Haley N. Proctor AIDAI.A. BERTUNA a KAMINS. P.C. • 546 FIFTH AVENUE. NEW YORK, NY. 10036 • T: 212-4660011 • F: 917-26I-4.932 • VAVW.AIDALALAW.COV SDNY_GM_02775903 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00262543 EFTA01340456