Case 1:20-cr-00330-PAE Document 246 Filed 04/23/21 Page1of13 Haddon, Morgan and Foreman, P.c Laura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 Fx 303.832.2628 www.hmilaw.com [email protected] HADDON MORGAN FOREMAN April 22, 2021 The Hon. Alison J. Nathan United States District Court Judge Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Request for Adjournment of 120 or 180 Days for Trial on the Non-Perjury Counts Dear Judge Nathan: Pursuant to the Court’s Order of April 20, 2012, counsel for Ghislaine Maxwell move for a continuance of the trial of the non-perjury counts for the reasons set forth below. The S2 indictment tripled the scope of the time frame at issue and expanded both the scope and type of conduct on trial, necessitating a re-review of millions of pages of discovery (most of which is not OCR or search capable), multiplying the type of experts needed for trial, and altering the COVID-challenging worldwide investigation to a new set of hundreds of witnesses. Layered onto this complexity, Ms. Maxwell still has not been provided an opportunity to review the entire set of discovery provided last November because the government-provided laptop and hard- drives are missing critical data and software; even her counsel is unable to access significant portions of the “old” discovery. Nor has Ms. Maxwell been afforded any opportunity to review the “new” 20,000-plus pages of, essentially, Brady material produced last week by the government related to 225 non-testifying witnesses. A continuance under these circumstances is a necessity for a fair trial on charges amounting to a potential life sentence. DOJ-OGR- 00003988