Case 1.20-cv-00484-3GK-DCF Document 66 Filed 08/12/20 Haddon, Page 1 of 2 and ec Laura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 rx 303.832.2628 www.hmflaw.com ImenningerehmfIcnv.com HADDON N N August 12, 2020 VIA ECF Hon. Debra Freeman United States Magistrate Judge Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 Re: Order of August 5, 2020 (ECF 62) 20-cv-00484 (JGK-DCF), Doe v. Indyke, et at Dear Judge Freeman: On behalf of defendant Ghislaine Maxwell, I write in reference to Your Honor's Order of August 5, 2020 which directed, in part, that the "parties ... confer further regarding deadlines contained in paragraphs 4 and 5, and to submit a joint letter regarding those deadlines by" today. Respectfully, I seek one additional week to address deadlines in the Scheduling Order as well as other issues raised by Your Honor during the initial scheduling conference of August 5, 2020. First and foremost, I have not had the ability to meaningfully confer with my client regarding her decision whether to request a stay in this action and, if so, whether it might be a request for a partial stay only as to her or a request for the entire action to be stayed. As the Court is aware, Ms. Maxwell is currently in pretrial detention in the Metropolitan Detention Center ("MDC"). There is no ability to visit her in person there, nor to have any video conference with her. While she is being allowed phone calls with counsel, they must be scheduled three days in advance. When one lawyer for her team is allowed a call, others are permitted to be patched through, but the calls are of limited duration and encompass a number of issues relevant to her two active civil cases, one active civil appeal and one active criminal case. A brief review of the dockets in those other matters reveals the number of issues on which she has an absolute right to consult with counsel. Oftentimes the calls are cut short by the MDC staff. Th