COHEN & GRESSER LLP

a COHEN & GRESSER LLP Mark S. Cohen Christian R. Evendell =EL December 4, 2020 The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Per the Court's order (Dkt. 81), the parties have conferred regarding the briefing schedule for Ghislaine Maxwell's renewed motion for release on bail. The defense respectfully requests that the hearing take place before the holidays and the government is amenable to that schedule. Accordingly, the parties propose the following briefing schedule: Defense submission: Government response: Defense reply due: Hearing: December 7, 2020 December 16, 2020 December 18, 2020 December 21, 2020 (subject to the Court's availability) Per the Court's order, the defense will send our submissions to the Court under seal on the dates mentioned above and will include a proposed redacted version of