574.pdf

Type

pdf

Source set

house-oversight-doj

Pages

3

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Searchable text available

OCR confidence

0.9373076770510151

Original source

Extracted text

Case 1:20-cr-00330-PAE Document574 _ Filed 01/10/22 Pagelof3 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 January 10, 2022 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, S2 20 Cr. 330 (AJN) Dear Judge Nathan: The parties respectfully submit this joint letter proposing a schedule for sentencing and resolution of the severed perjury counts, as directed by the Court. (Dkt. No. 567). This schedule is in addition to the Court’s schedule for post-trial motions, established by separate order. (Dkt. No. 571). Government Position The Government believes that the Court should order preparation of the Presentence Investigation Report (“PSR”) and schedule a sentencing proceeding approximately three to four months from today’s date. That schedule permits sufficient time for the preparation of the PSR and resolution of post-trial motions. In the event the defendant’s post-trial motions are denied, the Government is prepared to DOJ-OGR-00008811 

Case 1:20-cr-00330-PAE Document574 _ Filed 01/10/22 Page2of3 dismiss the severed perjury counts at the time of sentencing, in light of the victims’ significant interests in bringing closure to this matter and avoiding the trauma of testifying again. If any of the defendant’s post-trial motions are granted, the Government proposes that the parties be directed to promptly confer and propose a schedule for further proceedings. That schedule may depend on the manner in which the Court resolves such motions. Defense Position The defense requests that the Court delay setting a schedule for sentencing because there is a compelling basis for the Court to overturn Ms. Maxwell’s conviction and grant her a new trial based on the disclosures of Juror #50 during deliberations. The par…

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