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Case 22-1426, Document 1-2, 07/08/2022, 3344417, Page41 of 91 Christian) (Entered: 05/25/2021) 05/25/2021 | 295 | MEMORANDUM in Opposition by USA as to Ghislaine Maxwell re 292 MOTION to Dismiss and to Obtain the Relief Specified in her Supplemental Pre-Trial Motions Relating to the S2 Superseding Indictment.. (Rohrbach, Andrew) (Entered: 05/25/2021) 05/28/2021 | 296 | LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated May 28, 2021 re: Cover Letter for Omnibus Reply Memorandum in Support of the Defendant's Supplemental Pretrial Motions Relating to the S2 Superseding Indictment. (Everdell, Christian) (Entered: 05/28/2021) 06/02/2021 | 297 | ORDER as to Ghislaine Maxwell: Having considered the parties’ respective proposals, Dkt. No. 291, the Court hereby sets the following disclosure schedule: September 13, 2021: Disclosure of alleged victims’ identities (Government's proposal) October 11, 2021: Government's disclosure of Jencks Act and Giglio material, Rule 404(b) evidence and notice, co-conspirator statements, and Government witness list (Government's proposal) October 11, 2021: Government's disclosure of its proposed exhibit list (Defendant's proposal) October 18, 2021: Simultaneous filing of motions in limine (agreement of the parties) October 25, 2021: Simultaneous filing of proposed jury questionnaire and voir dire (agreement of the parties) November 1, 2021: Defense expert disclosures (Defendant's proposal) November 1, 2021: Responses to motions in limine (agreement of the parties) November 8, 2021: Simultaneous filing of requests to charge and verdict sheet (agreement of the parties) - November 8, 2021: Defense disclosures pursuant to Rules 16(b)(1)(A) and 16(b)(1)(B) materials (The Government proposed November 1, 2021; the Defendant proposed the close of the Government's case—in—chief) Close of the Government's case—in—chief: Defense witness list and 26.2 statements (Defendant's proposal) These dates establish a baseline for when the parties must disclose certain materials. Each of the parties has a continuing obligation to update all disclosures if they become aware of additional responsive materials. In addition, and as requested by the parties, the parties may bring issues to the Court's attention that arise after the deadline for motions in limine if the issues could not have been raised within the deadline set for in limine motions. (Motions due by 10/18/2021. Responses due by 11/1/2021) (Signed by Judge Alison J. Nathan on 6/2/2021) (ap) (Entered: 06/02/2021) 06/04/2021 | 298 | ORDER as to Ghislaine Maxwell: The Defendant's motion for an order authorizing the subpoena pursuant to Rule 17(c)(3) is DENIED. (Signed by Judge Alison J. Nathan on 6/4/2021) (See ORDER set forth) (ap) (Entered: 06/04/2021) 06/07/2021 | 299 | MANDATE of USCA (Certified Copy) as to Ghislaine Maxwell re: 173 Notice of Appeal, 113 Notice of Appeal. USCA Case Number 21-58; 21-770. Defendant—Appellant Ghislaine Maxwell appeals from orders of the District Court for bail pending trial. See Dkts. 1, 20. Upon due consideration, it is hereby ORDERED entered December 28, 2020 and March 22, 2021, which denied her renewed requests that the District Courts orders are AFFIRMED and that Appellants motion for bail, or in the alternative, temporary pretrial release pursuant to 18 U.S.C. § 3142(i), Dkt. 39, is DENIED. During oral argument, counsel for Appellant expressed concern that Appellant was improperly being deprived of sleep while incarcerated. To the extent Appellant seeks relief specific to her sleeping conditions, such request should be addressed to the District Court... Catherine O'Hagan Wolfe, Clerk USCA for the Second Circuit. Issued As Mandate: 6/7/2021. (nd) (Entered: 06/08/2021) Transmission of USCA Mandate to the District Judge re: 299 USCA Mandate. (nd) 06/08/2021 (Entered: 06/08/2021) 06/15/2021 | 300 | LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated 6/15/2021 re: Response to MDC Conditions Update (Sternheim, 301 Bobbi) (Entered: 06/15/2021) ORDER as to Ghislaine Maxwell: On June 7, 2021, the Government submitted an update on the Defendants conditions of confinement. It submitted it under temporary seal to permit the Defendant to propose redactions. On June 15, 2021, the Defendant proposed narrowly tailored redactions, which the Court adopts after applying the three—part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). The Government is ORDERED to publicly docket the redacted version of its June 7, 2021 letter by June 17, 2021. (Signed by 06/15/2021 DOJ-OGR- 00020427