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Case 1:20-cr-00330-PAE Document 246 Filed 04/23/21 Page4of13 The Hon. Alison J. Nathan April 22, 2021 Page 4 last continued February 4, 2021 because of COVID trial issues. The Court offered July 12, 2021 as a potential trial date. Counsel resisted this date because of Ms. Maxwell’s scheduled trial. J trial is scheduled to begin October 1, 2021 and continue until October 22, 2021. Based on comments made by the Courts in the J cases, and given the protracted nature of the litigations, it is highly unlikely that either case will resolve, nor that they will be continued to a later date. [J has been pending trial for over three years. WE case has been pending for more than six years. Defense counsel Bobbi Sternheim and AUSA Lara Pomerantz are scheduled to begin the trial of ee On October 4, 2021. The trial involves three defendants, two of whom are currently serving federal sentence, six charged and two dozen uncharged murders. The government has estimated 6-8 weeks of trial, but because the trial is subject to special protocols for jury selection during COVID, and the defendants and most of the witnesses are Spanish speakers and require the assistance of interpreters, counsel believes that the trial may extend beyond eight (8) weeks and, if not moved, could extend until January 2022. All defense counsel but one in JJ are amenable to a postponement; the remaining co- counsel cannot commit due to a late January trial date also before Judge Furman, which may resolve pre-trial. If Judge Furman is amenable to pushing the October 4 trial to follow this trial, Ms. Maxwell’s trial could begin November 8, 2021. B. Comparison of the S1 and S2 Indictments With the S2 indictment, the government significantly expanded the scope of this prosecution. The original indictment, and the first superseding indictment, charged a four-year conspiracy with two alleged co-conspirators. The second superseding indictment adds seven years to the scope of the alleged conspiracy. This is a material change that, standing alone, DOJ-OGR- 00003991