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Case 1:20-cr-00330-AJN Document 276 Filed 05/11/21 Page 3 of 4 LAW OFFICES OF BOBBI C. STERNHEIA\ Thanksgiving. The government does not explain why this witness is unavailable, and then they note, in a footnote, that the witness actually would be available to testify towards the end of the government’s case. In essence, that is less a “conflict” than a requirement that the government put on its case in a different order. It is also bitterly ironic that the government had been pushing for the earliest possible trial date to protect the victims’ interests, but now seeks to postpone it to keep the trial team together and to put its witnesses on in a preferred order. By contrast, pushing the trial to the end of November will have a severe and irreparable impact on Ms. Maxwell's defense. First, she will be detained longer. Second, the estimated four weeks for the government's case will result in Ms. Maxwell's defense being pressed to conclude before the holidays or worse, extending the case into the new year, which the Court already concluded was unwarranted delay. While the government may complete its case-in-chief before Christmas, the defense will not. This will cast defense counsel and the defense case in a negative light as jurors impatiently wait for the trial to conclude before Christmas, which it won’t. Third, starting on the Monday after Thanksgiving will pose impediments to the potential jury pool — many of whom will hopefully be able to travel to see family for the first time since before COVID -- and will disrupt travel plans for counsel and our families. Fourth, Ms. Maxwell's witnesses who will be traveling from various locations will be forced to book uncertain travel plans in the days leading up to — or after -- the holiday season. To accommodate the government’s vaguely articulated scheduling issues, we informed government counsel that we would consider starting on November 15, but no later. We firmly request that the Court set the trial to start on November 8" to ensure that the trial will conclude before Christmas. DOJ-OGR-00004119