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Case 22-1426, Document 3-2, 07/08/2022, 3344434, Page39 of 92 05/07/2021 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated May 7, 2021 re: Cover Letter for Omnibus Memorandum in Support of the Defendant's Supplemental Pretrial Motions Relating to the S2 Superseding Indictment (Everdell, Christian) (Entered: 05/07/2021) 05/10/2021 MEMO ENDORSEMENT as to Ghislaine Maxwell on 273 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated May 7, 2021 re: Cover Letter for Omnibus Memorandum in Support of the Defendant's Supplemental Pretrial Motions Relating to the S2 Superseding Indictment. ENDORSEMENT: The Government is hereby ORDERED to propose and justify any redactions by May 12, 2021. SO ORDERED. (Signed by Judge Alison J. Nathan on 5/10/2021) (nl) (Entered: 05/10/2021) 05/10/2021 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated May 10, 2021 re: Proposed Trial Date Document filed by USA. (Pomerantz, Lara) (Entered: 05/10/2021) 05/11/2021 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated 05/10/2021 re: Request for November 8th trial start date (Sternheim, Bobbi) (Entered: 05/11/2021) 05/11/2021 ORDER as to Ghislaine Maxwell: The Court has considered the parties' proposals regarding the commencement of trial. Dkt. Nos. 275, 276. For the reasons stated in the Government's letter, the Court will request November 29, 2021 from the Clerk's Office as the trial start datethat is the date (pending approval from the Clerk's Office consistent with the SDNY COVID protocols) that opening statements will be made to the jury. However, the Court will also request from the Clerk's Office that jury selection occur during the week of November 15. Counsel shall plan accordingly. The Court grants the Government's motion to exclude time until November 29, 2021. The Court finds that the ends of justice served by granting an exclusion from speedy trial computations for the period from today's date through November 29, 2021, outweigh the interests of the public and the Defendant in a speedy trial, because this time is necessary to permit the defense to continue to review discovery and other materials in light of the superseding indictment; to permit the parties to prepare and file motions in limine; to permit the parties to make and review additional pretrial disclosures; and to allow adequate time for the parties to prepare for trial. Time is therefore excluded under the Speedy Trial Act, 18 U.S.C. § 3161(h)(7)(A), until November 29, 2021. In order to ensure that there is no delay in the commencement of trial, the Court will adjust the current pre-trial schedule. So that the Court can resolve motions in limine in advance of the November 29th trial commencement date, any such motions shall be fully briefed no later than four weeks in advance of the anticipated trial commencement date of November 29. The parties shall meet and confer to propose adjustments to other pre-trial disclosures accordingly. The parties are hereby ORDERED to meet and confer for at least 30 minutes by phone regarding the overall pretrial disclosure schedule and submit a joint letter by May 14, 2021. The Court will accept only a joint letter with a joint proposal or with each sides views briefly stated. The letter must attest to the meet and confer. Any separately filed letters will be struck. SO ORDERED. (Time excluded from 5/11/2021 until 11/29/2021) (Signed by Judge Alison J. Nathan on 5/11/2021) (nl) (Entered: 05/11/2021) 05/12/2021 | 278 | LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated May 12, 2021 re: Proposed Redactions to Defendant's Supplemental Pre-Trial Motions Document filed by USA. (Pomerantz, Lara) (Entered: 05/12/2021) 05/13/2021 | 279 | ORDER as to Ghislaine Maxwell: On May 12, 2021, the Defendant submitted a response to the Government's May 4 and May 6 letters. See Dkt. Nos. 269, 271. She submitted it under temporary seal, though she noted that she is willing to file the response and its corresponding exhibits on the public docket. The Government is hereby ORDERED to notify the Court by May 14, 2021 whether it requests that any part of the Defendants submission be redacted or filed under seal; any such request must be justified by reference to the test articulated in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). SO ORDERED. (Signed by Judge Alison J. Nathan on 5/13/20201) (nl) (Entered: 05/13/2021) DOJ-OGR-00020525