Case 1:20-cr-00330-PAE Document 660 Filed 05/11/22 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 May 11, 2022 By ECF The Honorable Alison J. Nathan, Sitting by Designation 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, S2 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully moves for the exclusion of time for Counts Seven and Eight under the Speedy Trial Act, 18 U.S.C. § 3161(c)(1), until June 28, 2022—the scheduled date of sentencing. Although the Government currently intends to move to dismiss these counts at sentencing, as it has previously stated (see Dkt. No. 574), the Government seeks this exclusion of time in an abundance of caution, so the Act does not preclude prosecution in the unlikely event an intervening development occurs between now and sentencing which causes the Government to reconsider that position. Such an exclusion promotes the ends of justice by obviating any need for the parties and the Court to prepare for a second trial which, barring unforeseen developments, will not occur. See 18 U.S.C. § 3161(h)(7)(A). Defense counsel consents to this exclusion. 1 DOJ-OGR-00010414
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Case 1:20-cr-00330-PAE Document 660 Filed 05/11/22 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 May 11, 2022 By ECF The Honorable Alison J. Nathan, Sitting by Designation 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, S2 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully moves for the exclusion of time for Counts Seven and Eight under the Speedy Trial Act, 18 U.S.C. § 3161(c)(1), until June 28, 2022—the scheduled date of sentencing. Although the Government currently intends to move to dismiss these counts at sentencing, as it has previously stated (see Dkt. No. 574), the Government seeks this exclusion of time in an abundance of caution, so the Act does not preclude prosecution in the unlikely event an intervening development occurs between now and sentencing which causes the Government to reconsider that position. Such an exclusion promotes the ends of justice by obviating any need for the parties and the Court to prepare for a second trial which, barring unforeseen developments, will not occur. See 18 U.S.C. § 3161(h)(7)(A). Defense counsel consents to this exclusion. 1 DOJ-OGR-00010414
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Case 1:20-cr-00330-PAE Document 660 Filed 05/11/22 Page 2 of 2 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) 2 DOJ-OGR-00010415
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Case 1:20-cr-00330-PAE Document 660 Filed 05/11/22 Page 2 of 2 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) 2 DOJ-OGR-00010415