Case 1:20-cv-00484-JGK-DCF Document 89 Filed 12/22/20 Haddon, Page 1 of 4 and P.0 Laura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FA 303.832.2628 www.hmflaw.com Imenningenthmflaw.com H A D D O N A N Ilex December 22, 2020 VIA ECF Hon. John Koehl United States District Court Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 Re: Response to Letter of Plaintiff dated December 21 20-cv-484 (JGK-DCF), Jane Doe v. Darren K. Indyke, et al. Dear Judge Koeltl: On behalf of defendant Ghislaine Maxwell,/ write in response to plaintiff's "Letter Motion to Dismiss Pursuant to FRCP 41(a)(2)" dated December 21, 2020, wherein counsel makes a number of factually and legally inaccurate statements. Plaintiff previously wrote the Court on December 15, 2020, asking for a premotion conference regarding her intent to file a Motion to Dismiss pursuant to Rule 41(a)(2). This Court then issued an endorsement on December 17, 2020, advising that the parties need not have such a conference if they "submit a stipulation" of dismissal. In the absence of such a stipulation, the Court set a conference for January 12, 2021 at 3:30 p.m. See Doc. # 85. Without waiting for that conference and without negotiating with all parties a stipulation of dismissal, plaintiff now moves prior to the pre-motion conference to dismiss the case. She does not explain why she should be relieved of the rules requiring a pre-motion conference, nor her apparent disregard of the conference scheduled in January. Rather, she files her "Letter Motion to Dismiss" by levying baseless and false attacks on Ms. Maxwell and her counsel. As explained below, the parties have yet to complete conferring on the terms of a stipulated dismissal and therefore any ruling on the Letter Motion to Dismiss is premature. Plaintiff asserts that "Ms. Maxwell has found one excuse after another not to stipulate to the enclosed dismissal executed by the other parties." This is not