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Case 1:20-cr-00330-AJN Document 109 Filed 01/08/21 Page 2 of 2 The Honorable Alison J. Nathan January 8, 2021 Page 2 A brief extension of the time to appeal would also promote judicial efficiency because a third bail application may moot the need to appeal from the December 28 Order (or, in the event the third application is denied, permit a consolidated appeal). Conversely, denying the extension will require Ms. Maxwell to file a notice of appeal on January 11, 2021, which may lead to unnecessary parallel proceedings in this Court and in the Court of Appeals. We have conferred with the government and it objects to the requested extension. For these reasons, we respectfully request that the Court grant a 30-day extension of time under Rule 4(b)(4) of the Federal Rules of Appellate Procedure to file our notice of appeal of the Court’s order denying Ms. Maxwell’s renewed motion for bail. (Dkt. 104, 106).* Sincerely, /s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600 cc: All Counsel of Record (By ECF) ' In the event this motion is denied (or not granted by the close of business on January 11, 2021), Ms. Maxwell will file a notice of appeal to preserve her right to appeal the December 28, 2020 Order denying the renewed motion for bail (Dkt. 104, 106). DOJ-OGR-00002260