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Case 1:20-cr-00330-PAE Document 246 Filed 04/23/21 Page2of13 The Hon. Alison J. Nathan April 22, 2021 Page 2 Due to trial commitments that follow the July 12" trial date, counsel for Ms. Maxwell propose January 10, 2022 as the earliest firm trial date. However, we would be prepared, and would prefer, to begin trial on November 8, 2021, if the trial of 3 HE. scheduled to begin on October 4, 2021 before the Honorable Jesse M. Furman, were postponed.! We respectfully request that Your Honor confer with Judge Furman to determine whether such an accommodation is possible. I. Particularized facts supporting a continuance. A. Conflicting Trial Schedules The government originally estimated that a trial of the S1 indictment would last two weeks. Ms. Maxwell reluctantly agreed to set the trial out for a full year — despite the Court’s order of detention -- to ensure that she and her counsel would have sufficient time to analyze the government’s case and prepare for a defense. The case was scheduled to begin July 12, 2021 and continue for two weeks. Following the return of the S2 indictment, the government now estimates that “its case- in-chief will take up to three weeks,” and thus “propose[s] reserving four weeks for trial in this matter.” Dkt. 199 at 4. The government did not, apparently, take into account (a) the amount of time that will be required to empanel a jury in this high-publicity case, nor (b) account for the defense to have ample time to put on its own case. Simply put, defense counsel believe that a three-week government case means a total trial length of 5-6 weeks, allowing Ms. Maxwell ' Both Bobbi C. Sternheim, Esq. and AUSA Lara Pomerantz are counsel in |, a three- defendant case. The government estimates the trial will last 8 weeks. The defense believes it may take longer because all defendants and many witnesses do not speak English. Like the present case, the J case is subject to COVID protocols which could affect the trial date. DOJ-OGR-00003989