229 [DOJ-OGR-00003922—DOJ-OGR-00003926]

Case 1:20-cr-00330-PAE Document 229 Filed 04/21/21 Page1lof5 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 21, 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 Government respectfully submits this letter in response to the Court’s Order dated April 16, 2021, which directed the parties to negotiate a final schedule for all remaining pretrial matters in the above-referenced case. (Dkt. No. 207). Although the parties have agreed upon a schedule for several pretrial matters, the parties have not reached complete agreement on a full schedule. Accordingly, the Government is submitting this letter containing its proposal, and understands that defense counsel will write separately to convey the defense’s competing proposal. Based on conversations with defense counsel, the Government understands that the parties agree on the following proposed dates, assuming trial begins as scheduled on July 12, 2021: e The Government will provide expert notice to the defense by April 23, 2021. e The defense shall file any additional or supplemental motion briefing in light of the S2 Indictment by May 7, 2021. The Government shall file its responsive briefing by May 21, 2021. The defense shall file any reply briefing by May 28, 2021. e The Government will provide the defense with the identities of the victims referenced in the S2 Indictment by May 17, 2021. DOJ-OGR-00003922