Document 107

Case 1:20-cr-00330-AJN Document 107 Filed 12/31/20 Page 1 of 2 COHEN & GRESSER LLP Christian R. Everdell +1 (212) 957-7600 everdell@cohengresser.com 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com December 31, 2020 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: We write on behalf of our client, Ghislaine Maxwell, to respectfully request a two-week extension of time to file our pretrial motions and to shift the other motion deadlines forward by two weeks. We have conferred with the government, which has consented to the requested extension and the modified briefing schedule. The requested extension is necessary given the large volume of discovery produced by the government, which we are still reviewing, and to ensure that defense counsel can adequately discuss the motions with our client and have her review them. As the Court is aware, Ms. Maxwell was recently placed in quarantine for 14 days and in-person legal visits at MDC have been indefinitely suspended due to COVID, which has constrained our ability to confer with her. Under the Court's original briefing schedule, the defendant's pretrial motions were due on December 21, 2020, the government's response was due January 22, 2021, and the defendant's reply was due on February 5, 2021. (Dkt. 25). The Court agreed to move those deadlines by three weeks because the government needed additional time to finish producing discovery. (Dkt. 72). Under the current briefing schedule, the defendant's pretrial motions are due on January 11, 2020, the government's response is due February 12, 2021, and the defendant's reply is due on February 19, 2021. (Id.). We respectfully request that the Court so order the briefing schedule below. The next scheduled appearance before the Court is the first day of trial on July 12, 2021. January 25, 2021 Defendant's pretrial motions due February 26, 2021 Government's response due March 5, 2021 Defendant's reply due DOJ-OGR-00002255 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 107 Filed 12/31/20 Page 2 of 2 The Honorable Alison J. Nathan December 31, 2020 Page 2 Sincerely, /s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600 cc: All Counsel of Record (By ECF) DOJ-OGR-00002256