Case 1:20-cr-00330-AJN Document 202 Filed 04/15/21 Page 1 of 8
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April 15, 2021
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell
S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
We write in reply to the government’s April 9th letter opposing a trial continuance.
The defense has been steadfastly and diligently preparing for a July 12" trial based on the
original indictment, a date set on the condition that there would be no superseding indictment
adding substantive charges. The recently filed superseding indictment directly contravenes that
agreement and adds two new charges which vastly expand the relevant time period from a four-
year period in the 1990s to an eleven-year period stretching from 1994 to 2004. These additions
significantly alter the scope of the government’s case and necessarily shift the focus of the
defense’s trial preparation. Instead of being focused on mounting a defense to the allegations of
the three accusers from the 1990s, as we have been doing, the defense will now have to spend
considerable time and resources investigating allegations of new conduct in a completely
different time period involving numerous additional witnesses, and with all of the difficulties that
COVID restrictions still place on a meaningful defense investigation.
We do not want to postpone the trial but have no choice but to ask for a continuance. The
government bears responsibility for this need, having filed a late-breaking superseding
indictment based on a witness who has been known to the government since the Florida
DOJ-OGR-00002925