Case 1:20-cr-00330-AJN Document 276 Filed 05/11/21 Page 1 of 4
LAW OFFICES OF BOBBI C. STERNHEIA
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May 10, 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
$2 20 Cr. 330 (AJN)
Dear Judge Nathan:
We write in response to the government’s May 10, 2021 letter to the Court regarding the
trial start date. This Court ordered that the parties meet and confer regarding a trial start date and
to "agree to the earliest possible trial date this fall and to seek adjustments to other schedules in
order to facilitate an early fall trial start date." (Dkt. 266 at 3). Defense counsel attempted to
confer with the government in good faith to find a mutually acceptable date. We sent several
emails to counsel stating our reliance on our April 22d submission (Dkt. 246) where we specified
our conflicts and the justification for our request. By contrast, and despite our requests for
clarification, the government failed to provide any details to justify its request to delay the trial
start to November 29, 2021. Instead, the government filed a lengthy submission to the Court,
complete with case law citations, at 8:12 p.m., a few hours before the deadline for the “joint
letter.” Moreover, the government also audaciously seeks by way of their joint letter regarding
the trial date to re-litigate the schedule this Court has already crafted after hearing from the
parties both on submissions and in person, without even the courtesy of a motion for
reconsideration on that schedule.
For the reasons previously detailed in our April 22d letter to the Court, defense counsel’s
earliest possible — and preferred — trial start date is November 8". As the Court is aware, Judge
Furman moved my October 4" trial to March, clearing the way for this trial to start on November
DOJ-OGR-00004117