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Case 1:20-cr-00330-AJN Document 202 Filed 04/15/21 Page 6 of 8 LAW OFFICES OF BOBBI C. STERNHEIA\ witnesses, including potential FRE 404(b) witnesses, and trial exhibits, the government’s speculation about the length of the trial is entirely one-sided and lacking in any reliable estimate of a defense case. The government’s April 12" disclosure of information and statements regarding 226 witnesses containing exculpatory information requires intensive investigation. The delayed expansion of its prosecution and its unilateral expansion of the length of trial severely impacts defense preparation, trial readiness, and conflicts with other trial commitments. To assist the Court and defense counsel in accurately determining the length of trial, Ms. Maxwell requests that the Court order the government to disclose: a list of trial witnesses, its alleged FRE 404(b) evidence, and a list of potential trial exhibits. With this information the Court and the parties will be making decisions based on facts, not speculative promises. At the barest minimum, we require a 90-day continuance. In reliance on the firm trial date set by the Court at Ms. Maxwell’s arraignment on July 14", 2020, counsel prioritized the July 12, 2021 trial date, clearing and scheduling our calendars to avoid interference. Counsel have other clients and firm commitments to try cases specifically scheduled to follow the summer trial of this case. These commitments make us unavailable from September through December, and possibly spill over into January, make trying this case unlikely, if not impossible, before mid-January. We are extremely hard pressed to request any continuance, especially one which will prolong Ms. Maxwell’s miserable and punishing detention, but the need for time to properly prepare Ms. Maxwell’s defense as a result of the additional charges requires us to do so, causing Ms. Maxwell to reluctantly agree to this request. In addition, motion hearings, in limine motion practice, and any litigation regarding expert witnesses have not yet commenced, and issues regarding jury selection, including but not limited to a jury questionnaire, have not yet been settled. Yesterday, we met with the DOJ-OGR-00002930