DOJ-OGR-00021167.jpg
Extracted Text (OCR)
Case 22-1426, Document 70, 04/26/2023, 3505512, Paged of 8
13. On February 28, 2023, Maxwell filed her opening brief on appeal,
which contains approximately 19,950 words.
14. Maxwell’s brief raises at least five issues: (1) whether the indictment
should have been dismissed pursuant to a nonprosecution agreement signed by
Jeffrey Epstein and the U.S. Attorney’s Office for the Southern District of Florida;
(2) whether all counts were barred by the applicable statute of limitations; (3)
whether a juror’s misstatements during voir dire deprived Maxwell of her right to a
fair and impartial jury; (4) whether the District Court constructively amended two
counts of the indictment when responding to a jury note; and (5) whether the District
Court improperly applied an aggravating role adjustment when calculating the
applicable U.S. Sentencing Guidelines range.
15. Asthe foregoing summary reflects, there is factual and legal complexity
in the issues raised by Maxwell, and the Government’s responses to these arguments
require in-depth factual and legal analysis. Although the Government is endeavoring
to limit the size of its brief, a complete and useful response to Maxwell’s brief cannot
reasonably be accomplished in fewer than 20,000 words.
16. The Government is requesting the 30-day extension due to an
unavoidable scheduling conflict. Specifically, I am the attorney with primary
responsibility for drafting the Government response brief in this appeal. On April
18, 2023, trial for another matter in which I am counsel was scheduled to begin on
DOJ-OGR-00021167
Extracted Information
Document Details
| Filename | DOJ-OGR-00021167.jpg |
| File Size | 642.0 KB |
| OCR Confidence | 94.4% |
| Has Readable Text | Yes |
| Text Length | 1,582 characters |
| Indexed | 2026-02-03 20:07:56.211971 |