DOJ-OGR-00008861.pdf

--- Page 1 --- The extracted text is: **Header** Case 1:20-cr-00330-PAE Document 591 Filed 02/01/22 Page 1 of 1 **Firm Information** COHEN & GRESSER LLP Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com **Date and Address** February 1, 2022 The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 **Letter Body** Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Judge Nathan: We write on behalf of our client, Ghislaine Maxwell, to respectfully request a one-week extension of time until Friday, February 11, 2022 to file our post-trial motions. The motions are currently due on Friday, February 4, 2022. We have conferred with the government, which has consented to the requested extension. The requested extension is necessary because we need to meet with Ms. Maxwell in person to review work product related to the motions. In-person visits at the MDC only recently became available again this week. Due to other commitments, we are unable to meet with Ms. Maxwell until the end of this week. This is the defense's first request for an extension. We would consent to a similar one-week extension for the government to file its response. Sincerely, /s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600 **Footer** cc: All Counsel of Record (By ECF) 2087993.1 DOJ-OGR-00008861