EFTA00075314.pdf

Case 1:20-cr-00330-AJN Document 9 Filed 07/07/20 Page 1 of 2 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 7, 2020 VIA 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. Chislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in connection with the Court's Order dated July 6, 2020 (the "Order") (Dkt. 7) and the defendant's letter of July 6, 2020 (the "Defense Letter") (Dkt. 8). Pursuant to the Order, the parties have conferred regarding the scheduling of an initial proceeding in the above-captioned case. As set forth in the Defense Letter, the parties are available to proceed remotely on the morning of July 14, 2020. Additionally, the parties jointly respectfully propose the following briefing schedule in connection with the Government's Memorandum in Support of Detention, dated July 2, 2020 (Dkt. 4): • Defense response to be due by 3:00 p.m. on Friday, July 10, 2020 • Government reply to be due by 5:00 p.m. on Monday, July 13, 2020 The Government also respectfully renews and amends its request that the Court exclude time under the Speedy Trial Act, see Government Letter dated July 5, 2020 (Dkt. 5), between the defendant's arrest on July 2, 2020, and the revised proposed date of the arraignment, initial appearance, and bail hearing. In the interim, the Government intends to confer with defense counsel regarding the terms of a protective order and initial discovery, to facilitate the production EFTA00075314  Case 1:20-cr-00330-AJN Document 9 Filed 07/07/20 Page 2 of 2 Honorable Alison J. Nathan July 7, 2020 Page 2 of discovery, which will serve the interests of justice by facilitating the timely production of discovery materials. See 18 U.S.C. § 3161(h)(1)(F). I have conferred with defense counsel, who consent to this request. Very truly yours, AU o REY STRAUSS Act ng United States Attorney By: Assistant United States Attorneys Southern District of New York Tel: Cc: , counselfor defendant EFTA00075315