Case 1:20-cr-00330-AJN Document 166 Filed 03/15/21 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]
March 15, 2021
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
AO 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 reply
memoranda with accompanying exhibits:
1. Reply Memorandum in Support of Motion to Dismiss the Superseding Indictment for
Breach of the Non-Prosecution Agreement
2. Reply Memorandum in Support of Motion to Dismiss Counts One through Four of
the Superseding Indictment as Time-Barred
3. Reply Memorandum in Support of Motion Under the Due Process Clause to Suppress
All Evidence Obtained from the Government’s Subpoena to a and to
Dismiss Counts Five and Six
4. Reply Memorandum in Support of Motion to Dismiss Counts Five and Six of the
Superseding Indictment Because the Alleged Misstatements Are Not Perjurious as a
Matter of Law
5. Reply Memorandum in Support of Motion for a Severance of and Separate Trial on
Counts Five and Six of the Superseding Indictment
6. Reply Memorandum in Support of Motion to Strike Surplusage from the Superseding
Indictment
7. Reply Memorandum in Support of Motion to Dismiss Counts One Through Six of the
Superseding Indictment for Pre-Indictment Delay
8. Reply Memorandum in Support of Motion to Dismiss Either Count One or Count
Three of the Superseding Indictment as Multiplicitous
9. Reply Memorandum in Support of Motion to Dismiss the Superseding Indictment as
It Was Obtained in Violation of the Sixth Amendment
10. Reply Memorandum in Support of Motion for a Bill of Particulars and Pretrial
Disclosures
DOJ-OGR-00002759