DOJ-OGR-00004251.pdf

--- Page 1 --- The extracted text is: **Case 1:20-cr-00330-PAE** **Document 291** **Filed 05/21/21** **Page 1 of 13** **U.S. Department of Justice** **United States Attorney** **Southern District of New York** **BY ECF** **The Honorable Alison J. Nathan** **United States District Court** **Southern District of New York** **United States Courthouse** **40 Foley Square** **New York, New York 10007** **Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)** **Dear Judge Nathan:** **The parties respectfully submit this joint letter in response to the Court's Order dated May 11, 2021, which directed the parties to meet and confer for at least 30 minutes by phone regarding the overall pretrial disclosure schedule. (Dkt. No. 277). The parties met and conferred for approximately 80 minutes by telephone on this topic. Although the parties have agreed upon a schedule for some pretrial matters, the parties have not reached complete agreement on a full schedule. Accordingly, the parties set forth below the proposed dates on which the parties agree, the Government's proposal, and the defendant's proposal.** **The parties agree on the following proposed dates:** * The parties shall simultaneously file any motions in limine by October 18, 2021, or 6 weeks in advance of trial. The parties shall simultaneously file any responses to motions in limine by November 1, 2021, or 4 weeks in advance of trial. The parties will endeavor to have all motions fully briefed 4 weeks before trial in accordance with the Court's Order. The parties respectfully note that, as is the case in preparing for any trial, to the extent additional issues arise that require briefing, the parties will promptly bring such issues to the Court's attention. **DOI-OGR-00004251**