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Case 1:20-cr-00330-PAE Document 660 Filed 05/11/22 Pagelof2
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
May 11, 2022
By ECF
The Honorable Alison J. Nathan, Sitting by Designation
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, S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully moves for the exclusion of time for Counts Seven and Eight
under the Speedy Trial Act, 18 U.S.C. § 3161(c)(1), until June 28, 2022—the scheduled date of
sentencing. Although the Government currently intends to move to dismiss these counts at
sentencing, as it has previously stated (see Dkt. No. 574), the Government seeks this exclusion of
time in an abundance of caution, so the Act does not preclude prosecution in the unlikely event an
intervening development occurs between now and sentencing which causes the Government to
reconsider that position. Such an exclusion promotes the ends of justice by obviating any need for
the parties and the Court to prepare for a second trial which, barring unforeseen developments,
will not occur. See 18 U.S.C. § 3161(h)(7)(A). Defense counsel consents to this exclusion.
DOJ-OGR-00010414