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Caédasb: 2@2OrOCRRBPAGN DemuimemtBep Aiéeh1002232211 Paepege afdf 1 800 Third Avenue New York, NY 10022 COHEN & GRESSER LLP +1 212.957 7600 phone www.cohengresser.com Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com October 25, 2021 BY ECF The Honorable Alison J. Nathan Gane oniee United States District Court DOCUMENT | Southern District of New York ELECTRONICALLY FILED ; DOC #: 4 Foley Square DATE FILED:_10/26/21 New York, NY 10007 Re: United States v. Ghislaine Maxwell, 82 20 Cr. 330 (AJN) Dear Judge Nathan: SO ORDERED. Oy As 0) | verdict sheet, which are currently due on October 27, 10/26/21 . The government On October 20, 2021, the government provided the defense with its proposed jury charge. Because of the press of other deadlines in this case—including the motions in limine responses and replies, and the Rule 412 briefing—the defense requests an additional week to provide its counterproposals to the government and to submit the final proposed jury charge to the Court. The government and the defense have met and conferred and agreed that the defense will send the government a redlined version of the government’s proposed jury charge containing the defense’s counterproposals by 7:00 p.m. on November 1, 2021. The parties will submit the final joint proposed request to charge and verdict sheet, with the areas of continued disagreement shown in redline, on November 3, 2021. We respectfully request that the Court approve this revised schedule. Sincerely, /s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600 cc: All Counsel of Record (By ECF) DOJ-OGR-00005379