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EMERY CELLI BRINCKERHOFF & ABADY LLP
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they were raw.” Notably, in these emails, Ms. [REDACTED] mentions Professor Dershowitz, but she does not allege that she was trafficked to or had sex with him.

As you know, Ms. [REDACTED] provided this information, on the record, to a New York Post journalist with the expressed hope that it would be published. Although these allegations, if credible, would have been the story of a lifetime — videos and eye witness accounts of sexual misconduct by two presidential candidates, a former president, and one of the world’s leading entrepreneurs— the New York Post declined to publish them, presumably, and not surprisingly, because it did not find Ms. [REDACTED] credible. Nonetheless, thereafter, Ms. [REDACTED], represented by the same lawyers who represent the plaintiff in the above-captioned case, was permitted to testify that Professor Dershowitz had sex with her. These same lawyers have now provided documents to the Washington Post repeating the false charges, but have failed to provide the Post with the emails that fatally undermine them. These selective disclosures, and this use of the court’s protective and sealing orders “as a sword,” are manifestly improper.

Professor Dershowitz intends to pursue all available remedies for violations of the district court’s orders, including sanctions. That said, to remedy the gross imbalance in available information created by counsel’s improper disclosures, we ask that the parties’ counsel immediately agree to a stipulation, to be so-ordered by Judge Sweet, unsealing and removing the confidentiality designations from Ms. [REDACTED]s emails. This will allow for full public disclosure of these matters—where their falsity, exposed to the “sunlight” of public review, will be manifest—and it will permit Professor Dershowitz to respond fully to the accusations plaintiff’s counsel leaked to the Washington Post. Only with such full disclosure can the public decide who is telling the truth.

Please let us know your response to this request by noon on February 9, 2018.

Very truly yours,

[Signature]

Andrew G. Celli, Jr.

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