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Case 1:20-cr-00330-PAE Document 442 Filed 11/12/21 Page11o0f12 404(b) Notice by May 28, a date that was extended to October 11 after the continuance of the trial. Dkt. 229 at 3. The failure to comply with the requirements of the Rule has deprived Ms. Maxwell of the opportunity to litigate the issues on the timetable set by the Court. There is thus no "good cause" for extending the Government's ability to do so. This Court should exclude any evidence the government seeks belatedly to offer pursuant to Rule 404(b), or, alternatively should the Court find good cause for the failure of notice, grant Ms. Maxwell additional time to respond. As far as admissibility of the evidence referenced in the Letter as "direct evidence” of the charged crimes, Ms. Maxwell seeks leave to file such a Motion within two weeks. Dated: October 18, 2021 Respectfully submitted, s/ Jeffrey S. Pagliuca Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 225 Broadway, Suite 715 New York, NY 10007 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell DOJ-OGR-00006582