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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

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

July 28, 2022

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