Case 1:20-cr-00330-AJN Document 118 Filed 01/25/21 Page 1 of 2
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COHEN & GRESSER LLP +1 212.957 7600 phone
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Mark S. Cohen
Christian R. Everdell
+1 (212) 957-7600
[email protected]
[email protected]
January 25, 2021
VIA ECF
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:
On behalf of our client, Ghislaine Maxwell, we will be filing the following pretrial
motions with accompanying exhibits:
1. Motion to Dismiss the Superseding Indictment for Breach of the Non-Prosecution
Agreement
2. Motion to Dismiss Counts One through Four of the Superseding Indictment as Time-
Barred
3. Motion Under the Due Process Clause to Suppress All Evidence Obtained from the
Government’s Subpoena to ee and to Dismiss Counts Five and Six
4. Motion to Dismiss Counts Five and Six of the Superseding Indictment Because the
Alleged Misstatements Are Not Perjurious as a Matter of Law
5. Motion for a Severance of and Separate Trial on Counts Five and Six of the
Superseding Indictment
6. Motion to Strike Surplusage from the Superseding Indictment
7. Motion to Dismiss Counts One Through Six of the Superseding Indictment for Pre-
Indictment Delay
8. Motion to Dismiss Either Count One or Count Three of the Superseding Indictment
as Multiplicitous
9. Motion to Dismiss the Superseding Indictment as It Was Obtained in Violation of the
Sixth Amendment
10. Motion for a Bill of Particulars and Pretrial Disclosures
11. Motion Under the Fourth Amendment, Martindell, and the Fifth Amendment to
Suppress All Evidence Obtained from the Government’s Subpoena to
and to Dismiss Counts Five and Six
12. Motion to Dismiss Counts One through Four of the Superseding Indictment for Lack
of Specificity
DOJ-OGR-00002275