Document 280

Case 1:20-cr-00330-PAE Document 280 Filed 05/14/21 Page 1 of 2 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 May 14, 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, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The parties respectfully and jointly write to request an extension of time to file a letter in response to the Court's Order of May 11, 2021, requiring the parties to submit a joint letter regarding the overall pretrial schedule. (Dkt. No. 277). The joint letter is currently due on May 14, 2021, and the parties respectfully request an extension to May 21, 2021. No previous requests for an extension of this deadline have been made. DOJ-OGR-00004126 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 280 Filed 05/14/21 Page 2 of 2 Page 2 The parties seek this extension in order to permit continuation of productive discussions that the parties have already initiated regarding the pretrial schedule. The parties conferred yesterday for approximately 45 minutes by telephone on that topic. Although the conversation was productive, there remain multiple points of disagreement. The requested extension will permit the parties to consider each other's proposals as to certain deadlines, and to further confer with the aim of minimizing the points of disagreement that will need to be resolved by the Court. Respectfully submitted, AUDREY STRAUSS United States Attorney By: s/ Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York Cc: Defense counsel (By ECF) DOJ-OGR-00004127