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Case 1:20-cr-00330-PAE Document185 _ Filed 03/26/21 Page1of2
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
March 26, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Judge
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:
The Government respectfully writes to bring the Court’s attention to a recent decision by
Judge Crotty in United States v. Schulte, 17 Cr. 548 (PAC), which is attached hereto as Exhibit 1
(“Schulte Op.”). In that case, the defendant filed a motion to dismiss the indictment on November
16, 2020 (see 17 Cr. 548 (PAC), ECF No. 435), which was virtually identical in multiple respects
to the January 25, 2021 motion to dismiss the indictment filed by defendant Ghislaine Maxwell in
the above-captioned case (see 20 Cr. 330 (AJN), ECF No. 126). Like Maxwell, the defendant in
Schulte asserted, among other things, a claim under the Sixth Amendment of the Constitution,
arguing that the indictment should be dismissed because the grand jury sitting in White Plains
unfairly underrepresented Black and Hispanic individuals. Judge Crotty rejected those claims in
their entirety and denied the defendant’s motion to dismiss. Judge Crotty’s thorough, well-
reasoned decision supports the Government’s position in this case.
DOJ-OGR-00002820