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Case 1:20-cr-00330-PAE Document 345 Filed 10/14/21 Page3of3 The Honorable Alison J. Nathan October 14, 2021 Page 3 her counsel cannot adequately consult with her about the defense. Allowing Ms. Maxwell to file her Rule 412 motion 14 days before trial, as the Rule itself provides, is essential for counsel to effectively consult with Ms. Maxwell, to investigate and research what evidence they will seek to admit under Rule 412, as well as to comply with the several procedural steps required by the Rule. Accordingly, unless this Court orders otherwise, Ms. Maxwell will file her Rule 412 motion on or before November 15, 2021, as provided in Rule 412(c)(1)(B). Respectfully Submitted, y— Jeffrey S. Pagliuca CC: Counsel of Record (via ECF) DOJ-OGR-00005228