Case 1:20-cr-00330-PAE Document 246 Filed 04/23/21 Page1of13
Haddon, Morgan and Foreman, P.c
Laura A. Menninger
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364 Fx 303.832.2628
www.hmilaw.com
[email protected]
HADDON
MORGAN
FOREMAN
April 22, 2021
The Hon. Alison J. Nathan
United States District Court Judge
Southern District of New York
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Request for Adjournment of 120 or 180 Days for Trial on the Non-Perjury Counts
Dear Judge Nathan:
Pursuant to the Court’s Order of April 20, 2012, counsel for Ghislaine Maxwell move for
a continuance of the trial of the non-perjury counts for the reasons set forth below. The S2
indictment tripled the scope of the time frame at issue and expanded both the scope and type of
conduct on trial, necessitating a re-review of millions of pages of discovery (most of which is not
OCR or search capable), multiplying the type of experts needed for trial, and altering the
COVID-challenging worldwide investigation to a new set of hundreds of witnesses. Layered
onto this complexity, Ms. Maxwell still has not been provided an opportunity to review the entire
set of discovery provided last November because the government-provided laptop and hard-
drives are missing critical data and software; even her counsel is unable to access significant
portions of the “old” discovery. Nor has Ms. Maxwell been afforded any opportunity to review
the “new” 20,000-plus pages of, essentially, Brady material produced last week by the
government related to 225 non-testifying witnesses. A continuance under these circumstances is
a necessity for a fair trial on charges amounting to a potential life sentence.
DOJ-OGR- 00003988