Document EFTA 02838252¶
U.S. Department of Justice¶
United States Attorney Southern District of New York¶
The SiMa J. Mello Building One Saint Andrew’s Plaza New• York, New York 10007¶
May 11, 2022¶
By ECF¶
The Honorable Alison J. Nathan, Sitting by Designation 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, S2 20 Cr. 330 (AJN)¶
Dear Judge Nathan:¶
The Government respectfully moves for the exclusion of time for Counts Seven and Eight under the Speedy Trial Act, 18 U.S.C. § 3161(c)(1), until June 28, 2022—the scheduled date of sentencing. Although the Government currently intends to move to dismiss these counts at sentencing, as it has previously stated (see Dkt. No. 574), the Government seeks this exclusion of time in an abundance of caution, so the Act does not preclude prosecution in the unlikely event an intervening development occurs between now and sentencing which causes the Government to reconsider that position. Such an exclusion promotes the ends of justice by obviating any need for the parties and the Court to prepare for a second trial which, barring unforeseen developments, will not occur. See 18 U.S.C. § 3161(h)(7)(A). Defense counsel consents to this exclusion.¶
Respectfully submitted,¶
DAMIAN United States Attorney¶
By: st Maurene Convey Alison Moe Lam Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York¶
Cc: Defense Counsel (by ECF)¶