Document 163

Case 1:20-cr-00330-AJN Document 163 Filed 03/01/21 Page 1 of 2 COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com March 1, 2021 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 10-day extension of time until Monday, March 15, 2021 to file our reply to the Government's Omnibus Memorandum in Opposition to the Defendant's Pre-trial Motions. We have conferred with the government, which has consented to the requested extension. The requested extension is necessary because the government filed a lengthy response that included multiple exhibits and produced additional discovery that pertains to the motion response, all of which we will need time to review, analyze and discuss with our client. It will take several days for Ms. Maxwell to receive copies of these materials in the MDC. It will not be feasible for her to receive and review these lengthy materials, discuss them with counsel, and then read and provide comments on the draft replies in a week's time. 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 revised briefing schedule, the defendant's pretrial motions were due on January 11, 2020, the government's response was due February 12, 2021, and the defendant's reply was due on February 19, 2021. (Id.). On January 5, 2021, at the defense's request and with the consent of the government, the Court agreed to modify the briefing schedule and set the current deadlines: the defendant's pretrial motions were due on January 25, 2021, the government's response was due February 26, 2021, and the defendant's reply is due on March 5, 2021. (Dkt. 108). DOJ-OGR-00002744 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 163 Filed 03/01/21 Page 1 of 2 COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 www.cohengresser.com Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 3/1/21 March 1, 2021 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 10-day extension of time until Monday, March 15, 2021 to file our reply to the Government's Omnibus Memorandum in Opposition to the Defendant's Pre-trial Motions. We have conferred with the government, which has consented to the requested extension. The requested extension is necessary because the government filed a lengthy response that included multiple exhibits and produced additional discovery that pertains to the motion response, all of which we will need time to review, analyze and discuss with our client. It will take several days for Ms. Maxwell to receive copies of these materials in the MDC. It will not be feasible for her to receive and review these lengthy materials, discuss them with counsel, and then read and provide comments on the draft replies in a week's time. 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 revised briefing schedule, the defendant's pretrial motions were due on January 11, 2020, the government's response was due February 12, 2021, and the defendant's reply was due on February 19, 2021. (Id.). On January 5, 2021, at the defense's request and with the consent of the government, the Court agreed to modify the briefing schedule and set the current deadlines: the defendant's pretrial motions were due on January 25, 2021, the government's response was due February 26, 2021, and the defendant's reply is due on March 5, 2021. (Dkt. 108). DOJ-OGR-00002746 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 163 Filed 03/01/21 Page 2 of 2 The Honorable Alison J. Nathan March 1, 2021 Page 2 We now respectfully request that the deadline for filing the defendant's reply be moved to Monday, March 15, 2021. The next scheduled appearance before the Court is the first day of trial on July 12, 2021. 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-00002745 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 163 Filed 03/01/21 Page 2 of 2 The Honorable Alison J. Nathan March 1, 2021 Page 2 We now respectfully request that the deadline for filing the defendant's reply be moved to Monday, March 15, 2021. The next scheduled appearance before the Court is the first day of trial on July 12, 2021. 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) The Defendant's request is GRANTED. Her reply to the Government's Omnibus Memorandum in Opposition to the Defendant's Pre-trial Motions is now due on March 15, 2021. SO ORDERED. 3/1/2021 Alison J. Nathan United States District Judge DOJ-OGR-00002747