Case 1:15-cv-07433-LAP BSF Document 1046 Filed 04/03/20 Page 1 of 3 BOIES SCHILLER FLEXNER Sigrid S. McCawley Telephone: (954) 356-0011 Email: [email protected] April 3. 2020 VIA ECF The Honorable Loretta A. Preska District Court Judge United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska, Plaintiff writes pursuant to the Court's instructions during the March 31, 2020 telephone conference, to identify the first five motions for the unsealing process. The Original Parties have met and conferred multiple times to propose five motions pertaining to J. Doe 1 and J. Doe 2, as identified on the sealed Non-Party List, with which the Court may begin administering the Order and Protocol for Unsealing Decided Motions, Dkt. 1044. The Original Parties agree that the motion at Docket Entry 172, along with its Related Docket Entries (Dkts. 171, 173, 173-1, 189, 190, 190-1, 202, 203, 204-1, 211, 212, 212-1, 224), should be among the first five motions to be considered, but reached an impasse as to the remaining four motions. Plaintiff's position is that the Court should address the motions in an order that prioritizes those containing the most docket entries that involve the non-parties. To that end, Plaintiff proposes that the Court begin with the following five motions: Dkt. 172: Motion to Exceed Presumptive Ten Deposition Limit, Dkt. 315: Motion to Enforce Court Order and Direct Defendant to Answer Depo Questions, Dkt. 279: Motion for Adverse Inference Instruction, Dkt. 345: Motion to Compel Production of Documents Subject to Improper Objection, and Dkt. 659: Second Motion to Compel. To illustrate the utility of this approach, at the March 31, 2020, conference, the Court indicated that it was using the February 4, 2020, list of non-parties as its guide. See Mar. 31, 2020, Tr. at 4:8-10 ("Working off the Non-Party's list, I have been looking at the list that has the Doe