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 April 22, 2021 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the Court's Order dated April 20, 2021, which permitted the Government an opportunity to submit a response to the defense request for an adjournment of trial in the above-referenced case. (Dkt. No. 221). As previewed in its April 9, 2021 letter (Dkt. No. 199), the Government strenuously opposes any adjournment of the July 12, 2021 trial date in this case. Given both the recently granted severance and the Government's intention to present a streamlined case focused primarily on the experiences of four victims, trial on the non-perjury counts in indictment S2 20 Cr. 330 (AJN) (the "S2 Indictment") will not be materially lengthened by the addition of new charges. As previously noted, the Government has made and will continue to make significant efforts to ensure that the defense is able to prepare for trial as scheduled. Moreover, delay of the trial would prejudice the victims in this case, multiple of whom oppose any adjournment. Should the Court nevertheless grant the defense's request for an adjournment, however, the Government respectfully requests that trial be scheduled for March 2022 to ensure continuity of Government counsel at trial. EFTA00092734