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Extracted Text (OCR)
Case 22-1426, Document 70, 04/26/2023, 3505512, Page6 of 8
May 22, 2023. See United States v. Kenneth Wynder & Andrew Brown, 20 Cr. 470
(PKC) (S.D.N.Y.). Accordingly, in the remaining weeks prior to the current
deadline for the Government’s brief in this appeal, I will need to prepare for and
conduct a trial in another matter. A 30-day extension will permit the Government
to fulfill its obligations both to this Court and the district court by allowing the
Government time to prepare its response to Maxwell’s brief without interfering with
the preparation for and conduct of the Wynder & Brown trial. As noted above,
Maxwell sought and received permission to file her opening brief at the end of
February, more than four months after it ordinarily would have been due under this
Court’s rules. Accordingly, the comparatively modest adjournment requested by the
Government will not substantially prejudice Maxwell.
17. On April 19, 2023, the Government conferred by email with Diana
Samson, Esq., counsel for Maxwell, and she reported that Maxwell would not
oppose this motion if the Government also were to request that Maxwell receive an
extension of time to file her reply brief from July 20, 2023, to July 27, 2023.
Assuming the Government receives its requested extension to June 29, 2023, the
Government consents to the requested extension of time to file Maxwell’s reply brief
to July 27, 2023.
18. For the foregoing reasons, the Government respectfully requests (1)
leave to file an oversized brief of no more than 20,000 words, which is the
DOJ-OGR-00021168
Extracted Information
Document Details
| Filename | DOJ-OGR-00021168.jpg |
| File Size | 638.0 KB |
| OCR Confidence | 95.2% |
| Has Readable Text | Yes |
| Text Length | 1,574 characters |
| Indexed | 2026-02-03 20:07:56.583614 |