DOJ-OGR-00003990.jpg

Case 1:20-cr-00330-PAE Document 246 Filed 04/23/21 Page3of13 The Hon. Alison J. Nathan April 22, 2021 Page 3 ample opportunity to put on a defense case and any rebuttal. The July 12 date (even assuming that is actually the date that the COVID-protocol allows for a start) no longer works. Defense counsel Jeffrey Pagliuca has a jury trial scheduled to begin on August 17, 2021. It was scheduled to accommodate the 2-week July 12 trial of Ms. Maxwell. [i ee is an alleged felony theft from the elderly scheduled to begin on August 17, 2021. This is a matter that has been continued a number of times for various reasons related to prior defense counsel of record. Mr. Pagliuca is J only trial counsel. It is likely that should Ms. Maxwell’s July 12 trial be delayed for a week or last longer than the original two weeks predicted by the government, counsel would be unavailable for yj a ia. Further, Mr. Pagliuca together with defense counsel Laura Menninger, who have served as counsel for Ms. Maxwell since 2015, have two scheduled trials that preclude a request for less than a 120-day adjournment here. These trials also were scheduled specifically to accommodate the July 12 Maxwell trial schedule. 42 U.S.C. § 1983 action against a Denver Police Department sergeant and the City and County of Denver. The events in question occurred in 2013, counsel has represented x, the case has been twice appealed to the 10th Circuit by defendants, and the trial has been re-scheduled twice due to COVID protocols in the U.S. District Court for the District of Colorado. See Dkt. Nos. 218, 231. The trial is scheduled to commence on September 13, 2021 and last until September 29, 2021. The Final Pretrial Conference is scheduled for August 25, 2021. EE is 2 homicide trial that was filed in 2018. The defendant is charged with first degree murder after deliberation which, under Colorado law, carries one penalty, life imprisonment without possibility of parole. This case also has been the subject of a Colorado Supreme Court interlocutory appeal and has twice been re-scheduled due to COVID protocols and the unavailability of a material witness due to COVID. [ trial was DOJ-OGR-00003990