Document 652

Case 1:20-cr-00330-PAE Document 652 Filed 04/01/22 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 April 1, 2022 By ECF The Honorable Vernon S. Broderick United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007B Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (VSB) Dear Judge Broderick: The Government respectfully submits this letter in opposition to the defendant's April 1, 2022 letter, which requests a stay of this matter based on a Paramount Plus trailer. The Court should reject the defendant's application, which is premised on the pure speculation that an unreleased interview with Juror 50 could potentially contain information relevant to the defendant's motion. The Court has conducted a thorough hearing, at which the Court asked Juror 50 detailed questions about all subjects relevant to the pending motion. The Court has completed the fact-finding process, and there is no basis on the current record to conclude that a stay is warranted. Indeed, the defendant's application contains no legal or factual support beyond the citation to a Paramount Plus trailer. If the defendant obtains new information, she may file any appropriate 1 DOJ-OGR-00010322 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 652 Filed 04/01/22 Page 2 of 2 motions at that time, but it is inappropriate to stay this matter based on nothing more than the defendant's conjecture. The Government strongly opposes a stay of this matter. The application should be denied. Respectfully submitted, DAMIAN WILLIAMS 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)