DOJ-OGR-00021167.pdf

Case 22-1426, Document 70, 04/26/2023, 3505512, Page5 of 8 13. On February 28, 2023, Maxwell filed her opening brief on appeal, which contains approximately 19,950 words. 14. Maxwell's brief raises at least five issues: (1) whether the indictment should have been dismissed pursuant to a nonprosecution agreement signed by Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida; (2) whether all counts were barred by the applicable statute of limitations; (3) whether a juror's misstatements during voir dire deprived Maxwell of her right to a fair and impartial jury; (4) whether the District Court constructively amended two counts of the indictment when responding to a jury note; and (5) whether the District Court improperly applied an aggravating role adjustment when calculating the applicable U.S. Sentencing Guidelines range. 15. As the foregoing summary reflects, there is factual and legal complexity in the issues raised by Maxwell, and the Government's responses to these arguments require in-depth factual and legal analysis. Although the Government is endeavoring to limit the size of its brief, a complete and useful response to Maxwell's brief cannot reasonably be accomplished in fewer than 20,000 words. 16. The Government is requesting the 30-day extension due to an unavoidable scheduling conflict. Specifically, I am the attorney with primary responsibility for drafting the Government response brief in this appeal. On April 18, 2023, trial for another matter in which I am counsel was scheduled to begin on 4 DOJ-OGR-00021167