United States v. Maxwell, No. 120-cr-00330 (S.D.N.Y. 2020)/194.pdf

Haddon, Morgan and Foreman, P.C Laura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com LMenninger@hmflaw.com April 5, 2021 The Hon. Alison J. Nathan United States District Court Judge Southern District of New York 40 Foley Square New York, NY 10007 Re: Unopposed Request for One-Week Continuance of Arraignment United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Counsel for Ms. Maxwell writes to request that the arraignment of the S2 Indictment (Dkt. 193), tentatively scheduled for April 16, 2021, be calendared for April 23, 2021. The government does not oppose this request. At present, counsel for Ms. Maxwell has a conflict on April 16, 2021 in Colorado due to a currently-scheduled hearing that day. Additionally, other members of Ms. Maxwell’s defense team have previously scheduled a review of the physical evidence the weeks of April 12 and 19 th in the courthouse and would prefer to complete that review prior to the arraignment. Counsel appreciates that an in-person arraignment requires some logistical arrangements which may be accommodated by the requested date. Further, the extra time will permit Ms. Maxwell’s family members to adjust their schedules and make travel arrangements to attend the court proceedings. Ms. Maxwell respectfully requests that the Court hold the arraignment on the S2 Indictment on April 23, 2021, or such other date convenient to the Court during the week of Case 1:20-cr-00330-PAE Document 194 Filed 04/05/21 Page 1 of 2 HADDON MORGAN FOREMAN The Hon. Alison J. Nathan April 5, 2021 Page 2 April 19, 2021. Respectfully submitted, Laura A. Menninger CC: Counsel of Record Case 1:20-cr-00330-PAE Document 194 Filed 04/05/21 Page 2 of 2 ( ' (j