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_Case 1:20-cr-00330-PAE Document 235 Filed 04/22/21 Page 1 of 10
: 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 22, 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 20, 2021, which permitted the Government an opportunity to submit a response to the
defense request for an adjournment of trial in the above-referenced case. (Dkt. No. 221). As
previewed in its April 9, 2021 letter (Dkt. No. 199), the Government strenuously opposes any
adjournment of the July 12, 2021 trial date in this case. Given both the recently granted severance
and the Government’s intention to present a streamlined case focused primarily on the experiences
of four victims, trial on the non-perjury counts in indictment S2 20 Cr. 330 (AJN) (the “S2
Indictment”) will not be materially lengthened by the addition of new charges. As previously
noted, the Government has made and will continue to make significant efforts to ensure that the
defense is able to prepare for trial as scheduled. Moreover, delay of the trial would prejudice the
victims in this case, multiple of whom oppose any adjournment. Should the Court nevertheless
grant the defense’s request for an adjournment, however, the Government respectfully requests
that trial be scheduled for March 2022 to ensure continuity of Government counsel at trial.
DOJ-OGR-00003943