DOJ-OGR-00020603.pdf

--- Page 1 --- The extracted text is as follows: **Header:** UNITED STATES COURT OF APPEALS SECOND CIRCUIT **Case Information:** Case 22-1426, Document 40, 01/12/2023, 3451920, Page2 of 4 **Docket Number:** 22-1426 **Affirmation in Support of Defendant-Appellant's Motion to Extend Time to File Brief:** AFFIRMATION IN SUPPORT OF DEFENDANT-APPELLANT'S MOTION TO EXTEND TIME TO FILE BRIEF **Against:** GHISLAINE MAXWELL, **Defendant-Appellant:** JOHN M. LEVENTHAL, an attorney duly admitted to practice law in the State of New York and a partner of the law firm of AIDALA, BERTUNA & KAMINS PC., attorneys for Defendant-Appellant, GHISLAINE MAXWELL, hereby affirms the following statements, under penalties of perjury: 1. That I am a partner at the law firm of AIDALA, BERTUNA & KAMINS P.C., attorneys for Defendant-Appellant, Ghislaine Maxwell (hereinafter "Appellant"), and as such, am fully familiar with the facts and circumstances of this action. 2. On July 15, 2022, I filed a Notice of Appearance in this matter so that trial counsel could withdraw. 3. On July 28, 2022, I filed a scheduling request asking that Appellant's brief be due on January 30, 2023, based on the size of the record. 4. Soon after this Court granted our scheduling request, we were notified that the New York Court of Appeals had granted us leave on another matter which also involved a voluminous record and several issues of law which required substantial time and resources. 5. The work of our small team of experienced appellate attorneys has been divided between these two cases. In addition, one of our appellate attorneys is dealing with a serious health condition. This has impacted his ability to work on the case. 6. Another factor that has affected our ability to complete this brief by the current deadline is the fact that we have been unable to obtain certain documents and materials from the Government, which are necessary for our defense. 7. We have made every effort to obtain these documents and materials, but the Government has failed to provide them to us in a timely manner. 8. As a result, we are requesting an extension of time to file our brief. 9. We believe that this extension is necessary to ensure that we can fully and fairly present our defense. 10. We are confident that, with this extension, we will be able to complete our brief and present our defense in a timely and effective manner. **Footer:** DOJ-OGR-00020603