DOJ-OGR-00020596.pdf

Case 22-1426, Document 30, 07/28/2022, 3356263, Page 1 of 2 Aidala, Bertuna & Kamins, P.C. ARTHUR L. AIDALA* MARIANNE E. BERTUNA* HON. BARRY KAMINS (RET.) HON. JOHN M. LEVENTHAL (RET.) JOHN S. ESPOSITO* MICHAEL T. JACCARINO IMRAN H. ANSARI DIANA FABI SAMSON** ANDREA M. ARRIGO* LINO J. DE MASI MICHAEL F. DIBENEDETTO* *ALSO ADMITTED IN NEW JERSEY **ALSO ADMITTED IN CONNECTICUT 546 FIFTH AVENUE NEW YORK, NY 10036 TELEPHONE: (212) 486-0011 FACSIMILE: (917) 261-4832 WWW.AIDALALAW.COM July 28, 2022 8118 - 13TH AVENUE BROOKLYN, NEW YORK 11228 TEL: (718) 238-9898 FAX: (718) 921-3292 OF COUNSEL JOSEPH A. BARATTA ANTOINETTE LANTERI WILLIAM R. SANTO PETER S. THOMAS LAWRENCE SPASOJEVICH SENIOR COUNSEL LOUIS R. AIDALA JOSEPH P. BARATTA Catherine O'Hagan Wolfe Clerk of Court Thurgood Marshall United States Court House 40 Foley Square New York, New York 10007 Re: Briefing Schedule Request, USA v. Ghislaine Maxwell, Case 22-1426 Dear Ms. O'Hagan Wolfe, I am appellate counsel for Defendant-Appellant Ghislaine Maxwell. I was not trial counsel for Ms. Maxwell. I filed an Acknowledgement and Notice of Appearance on July 15, 2022. The Clerk required that I file a Form B on that date, as well, although I did not, at that time, have any information concerning the transcripts. Pursuant to Local Rule 31.2(a)(1)(A), the ready date for this case was July 15, 2022. Accordingly, I have until July 29, 2022, to file this briefing schedule request. Pursuant to Local Rule 31.2(a)(1)(A), I can request no more than 91 days from the ready date as the deadline for filing Appellant's Brief. That date would be October 14, 2022. Pursuant to Local Rule 31.2(a)(1)(D), however, I am permitted to request a later deadline to file Appellant's Brief if the case involves a voluminous record or extreme hardship would result. I request that the Court permit me to file Appellant's Brief on Monday, January 30, 2023, for the following reasons which I believe satisfy both preconditions identified by the rule. First, as noted, I am new counsel and have obtained access to the complete file on this case only this week. As new counsel unfamiliar with the case, I must therefore scrutinize the entire record in order to provide my client with the most competent and effective representation on appeal. Second, the record is voluminous in that it involves at least 3,824 pages of transcript including pretrial hearings, voir dire, trial, sentence, and post-conviction proceedings. In addition, the Docket Report consists of 738 entries, including but not limited to dozens of fully briefed pretrial motions and motions in limine, comprising hundreds of pages of legal analysis on important issues. Third, I must conduct my own research in order to determine what issues I believe provide my client with the best chance of prevailing on appeal. This is especially important given this Court's rules concerning the size of Appellant's Brief. Fourth, I have not been able to meet with my client as she was prematurely transferred to Tallahassee, Florida by the Federal Bureau of Prisons over this past weekend, a DOJ-OGR-00020596