Case 1:20-cr-00330-AJN Document 10% Filed 02/65/20 Page 1 of 2 800 Third Avenue New York, NY 10022 COHEN & GRESSER LLP +1 212.957 7600 phone www.cohengresser.com Christian R, Everdell USDC SDNY +1 (212) 957-7600 DOCUMENT [email protected] ELECTRONICALLY FILED DOC #; DATE FILED: 1/5/21] December 31, 2020 BY ECF The Honorable Alison J. Nathan United States District Court Souther District of New York United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: We write on behalf of our client, Ghislaine Maxwell, to respectfully request a two-week extension of time to file our pretrial motions and to shift the other motion deadlines forward by two weeks. We have conferred with the government, which has consented to the requested extension and the modified briefing schedule. The requested extension is necessary given the large volume of discovery produced by the government, which we are still reviewing, and to ensure that defense counsel can adequately discuss the motions with our client and have her review them. As the Court is aware, Ms. Maxwell was recently placed in quarantine for 14 days and in-person legal visits at MDC have been indefinitely suspended due to COVID, which has constrained our ability to confer with her. Under the Court’s original briefing schedule, the defendant’s pretrial motions were due on December 21, 2020, the government’s response was due January 22, 2021, and the defendant’s reply was due on February 5, 2021. (Dkt. 25). The Court agreed to move those deadlines by three weeks because the government needed additional time to finish producing discovery. (Dkt. 72). Under the current briefing schedule, the defendant’s pretrial motions are due on January 11, 2020, the government’s response is due February 12, 2021, and the defendant’s reply is due on February 19, 2021. Ud.). We respectfully request that the Court so order the briefing schedule below. The