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Case 1:20-cr-00330-PAE
Document 291 ‘Filed 05/21/21 Page1of13
U.S. Department of Justice
United States Attorney
Southern District of New York
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
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
May 21, 2021
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The parties respectfully submit this joint letter in response to the Court’s Order dated May
11, 2021, which directed the parties to meet and confer for at least 30 minutes by phone regarding
the overall pretrial disclosure schedule. (Dkt. No. 277). The parties met and conferred for
approximately 80 minutes by telephone on this topic. Although the parties have agreed upon a
schedule for some pretrial matters, the parties have not reached complete agreement on a full
schedule. Accordingly, the parties set forth below the proposed dates on which the parties agree,
the Government’s proposal, and the defendant’s proposal.
The parties agree on the following proposed dates:
e The parties shall simultaneously file any motions in /imine by October 18, 2021, or
6 weeks in advance of trial. The parties shall simultaneously file any responses to
motions in limine by November 1, 2021, or 4 weeks in advance of trial. The parties
will endeavor to have all motions fully briefed 4 weeks before trial in accordance
with the Court’s Order. The parties respectfully note that, as is the case in preparing
for any trial, to the extent additional issues arise that require briefing, the parties
will promptly bring such issues to the Court’s attention.
DOJ-OGR-00004251