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Case 1:19-cv-10474-NRB Document 10 Filed 12/11/19 Page 1 of 3
BSF
BOIES
SCH ILLER
FLEXNER
Telephone: (212) 446-2300
Email: jischiller@bsfllp.com
December 11, 2019
VIA ECF
The Honorable Naomi Reice Buchwald
District Court Judge
United States District Court
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: Farmer v. Indyke et al.,
Case No. 19-cv-10474
Dear Judge Buchwald,
Plaintiff Maria Farmer writes in response to non-party Alan Dershowitz’s request for a
pre-motion conference to seek permission to file a motion for limited intervention, to strike
paragraph 39 of Plaintiff’s complaint, and for sanctions. Dkt. 9.
Paragraph 39 of Maria’s complaint states that “[i]n her position at the front door” of
Epstein’s mansion, “she observed that [Ghislaine] Maxwell was regularly bringing school-aged
girls to the mansion,” and that Maria “observed Alan Dershowitz, a lawyer, on a number of
occasions, and observed that he would go upstairs at the same time the young girls were there.”
These allegations are directly relevant to establishing Maria’s claims, and bolster the plausibility
of the complaint’s allegations as to the existence of a sex-trafficking conspiracy, the abuse Maria
suffered, and how Epstein and his co-conspirators were able to coerce her to remain silent. The
allegations serve a legitimate purpose, and are in no way “redundant, immaterial, impertinent, or
scandalous.” Fed. R. Civ. P. 12(f).
For the following reasons, the Court should deny Dershowitz’s request for a conference
and his proposed motions in their entirety.
I. Dershowitz Is Not Entitled to Intervene in This Matt
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