From: BOBBI C STERNHEIM To: Cc: Christian Everdell , Jeff Pagliuca Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Date: Sun, 09 May 2021 16:14:34 +0000 Good afternoon- In our 4/22 letter, we provided specific details concerning cases and trial dates to justify our request for a continuance to 11/8. Beyond a vague statement regarding consideration of availability of witnesses and counsel, you have provided no specific details why the government cannot proceed to trial on 11/8. Starting the trial on 11/29 - besides disrupting Thanksgiving holiday plans - will push the trial to the end of the year and possibly into the new year, interfering with Christmas and New Year's plans, as COVID did last year. This will cast the defense and defense case in a negative light as jurors impatiently wait for the trial to conclude before Christmas, which it won't. Our previous email explained our reasons for firmly pressing the 11/8 trial date, but as an accommodation, we would consider starting on 11/15, but no later. For now, we will not agree to exclusion of speedy trial time beyond 11/8. These scheduling conflicts can be easily eliminated by consenting to bail for Ms. Maxwell. It is unclear why the scheduling order, which contemplated a continuance, should be altered. As previously discussed and raised with the Court, we need to review of 3500 material and exhibits before determining the need to call any experts. Enjoy the day. Bobbi BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Sternheim ••Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely. Please use email or fax, instead of regular mail, for all correspondence during this time. We continue to work regular business hours throughout this situation. Thank you for your consideration. Our best wishes for your good health and well being. This message and any attached documents contain information from the Law Offices of Bobbi C. Stemheim