Caédasb: 2@2OrOCRRBPAGN DeomuimamtBep Ariéeh100223201 Paepage afdf 1
800 Third Avenue
New York, NY 10022
COHEN & GRESSER LLP +1 212.957 7600 phone
www.cohengresser.com
Christian R. Everdell
+1 (212) 957-7600
[email protected]
October 25, 2021
BY ECF
The Honorable Alison J. Nathan Hane oniee
United States District Court DOCUMENT |
Southern District of New York ELECTRONICALLY FILED |
‘ DOC #:
4 Foley Square DATE FILED:_10/26/21
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 82 20 Cr. 330 (AJN)
Dear Judge Nathan: SO ORDERED.
10/26/21
On October 20, 2021, the government provided the defense with its proposed jury charge.
Because of the press of other deadlines in this case—including the motions in limine responses
and replies, and the Rule 412 briefing—the defense requests an additional week to provide its
counterproposals to the government and to submit the final proposed jury charge to the Court.
The government and the defense have met and conferred and agreed that the defense will
send the government a redlined version of the government’s proposed jury charge containing the
defense’s counterproposals by 7:00 p.m. on November 1, 2021. The parties will submit the final
joint proposed request to charge and verdict sheet, with the areas of continued disagreement
shown in redline, on November 3, 2021. We respectfully request that the Court approve this
revised schedule.
Sincerely,
/s/ Christian Everdell
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue, 21st Floor
New York, New York 10022
(212) 957-7600
ce: All Counsel of Record (By ECF)
DOJ-OGR-00005379