Case 1:15-cv-07433-LAP Document 1045 Filed 04/03/20 Page 1 of 2 Haddon. HADDON N N and S P.c Laura A. MennInger I50 East 10th Avenue Denver. Colorado 80203 PH 303.831.7360 n 303.832.2628 www.hmllaw.com [email protected] April 3, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Order and Protocol (DE 1044) and March 31, 2020 Status Conference v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: On behalf of Defendant Ghislaine Maxwell, I write pursuant to this Court's Telephone Conference of March 31, 2020, to propose a sequence for the Court's consideration of motions under its Order and Protocol (DE 1044). Unfortunately, counsel for the original parties were unable to reach an agreement as to the sequence of motions. I also write to submit a joint proposed redacted Decided Motions List. First, Ms. Maxwell proposes that the Court proceed in chronological order and consider the first five motions (together with any related, sealed documents) that mention J. Does 1 & 2. Those five motions are DEs 143, 164, 172, 199 and 230. Accompanying this letter (and filed under seal) are two charts listing all the filings from the Decided Motions List which contain references to J. Does 1 & 2, plus an additional column which pinpoints the reference in each filing to Does 1 & 2.' The charts also include the original Decided Motion, regardless of whether it references J. Doe 1 or 2, so that the Court has the benefit of the "Related Docket #" column listing the related filings. Ms. Maxwell submits that consideration of the motions in chronological order is the most logical, efficient and fair method to adopt. Plaintiff's counsel proposes an ad hoc approach in which filings appear to be selected in order to speed up review of materials that Plaintiff would like to see unsealed first rather than a review method that favors efficiency and objectivity. Taking motions out of sequence