Case 1:20-cr-00330-PAE Document 230
COHEN & GRESSER LLP
Christian R. Everdell
+1 (212) 957-7600
[email protected]
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
AO Foley Square
New York, NY 10007
Filed 04/21/21 Page1lof3
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
April 21, 2021
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
Pursuant to the Court’s Opinion and Order, dated April 16, 2021 (Dkt. 207), the parties
have met and conferred about a schedule for the remaining pretrial disclosures and other pretrial
motions practice. Although Ms. Maxwell maintains that a continuance of the trial date is
necessary to ensure a fair trial for the reasons we will set forth in our letter to the Court tomorrow,
we have discussed with the government disclosure dates assuming the trial begins on July 12,
2021.
The following schedule indicates the areas of agreement and disagreement between the
parties. Areas of agreement include dates proposed by both parties (in bold). Areas of
disagreement include dates proposed by the defense (in bold) and dates proposed by the
government (underlined).
Parties Agree
Government Expert Witness Disclosure
April 23 — Government expert disclosure
DOJ-OGR-00003927