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Case 1:20-cr-00330-PAE Document 266 Filed 05/03/21 Page2of3 that the conspiracies charged in Counts 1 and 3 extended to 2004 (the S1 charged through 1997), identifying a fourth alleged victim, Minor Victim-4. It also adds two new charges: Count 5 of the S2 Indictment charges Maxwell with participating in a sex trafficking conspiracy between 2001 and 2004, and Count 6 charges Maxwell with participating in the sex trafficking of a minor or aiding and abetting the same. Dkt. No. 187. These additions will require the defense to (1) review a substantial amount of discovery that is now potentially relevant as a result of the S2 Indictment; (2) re-review discovery that it had previously considered in light of the changes to the case against her; (3) conduct new investigations based on the new charges, including potential interviews of new witnesses; and (4) re-evaluate her trial preparation and strategy. Second, although jury trials have resumed in the district and conditions in MDC and around the country are improving, the defendant’s and defense counsel’s preparation efforts to date have been and to some extent continue to be hampered by the effects of the COVID-19 pandemic. As the Government indicated in explaining the delay in filing the new charges, travel constraints and other safety concerns resulting from the pandemic have slowed trial preparation and complicated the logistics of conducting investigations. See Dkt. No. 199 at 2. Third, defense counsel must balance preparing for trial with considering and preparing any supplemental pre-trial motions in response to the new charges contained in the S2 Indictment. Although the perjury counts were recently severed, the Court cannot conclude that this sufficiently offsets the additional burdens placed on the defense as a result of the new charges and expanded timeframe resulting from the S2 indictment. The Court is very mindful of the countervailing considerations that require that any adjournment be no longer than necessary. For one, the Defendant, whose counsel strenuously request the adjournment, is detained pre-trial. Moreover, with many lawyers on both sides of DOJ-OGR-00004082