209.pdf

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pdf

Source set

house-oversight-doj

Pages

5

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Searchable text available

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0.9275333600268861

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Extracted text

Case 1:20-cr-00330-PAE Document 209 _ Filed 04/16/21 Pagelof5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, y 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. REPLY MEMORANDUM OF LAW IN SUPPORT OF MS. MAXWELL’S MOTION TO DISMISS COUNTS ONE THROUGH SIX OF THE SUPERSEDING INDICTMENT FOR PRE-INDICTMENT DELAY Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell DOJ-OGR-00003753 

Case 1:20-cr-00330-PAE Document 209 _ Filed 04/16/21 Page2of5 The significant delay in prosecuting these charges has substantially prejudiced Ms. Maxwell, and the government has offered no legitimate reason for the tactical delay. Indeed, many of the arguments made by the government in response to Ms. Maxwell’s motions reveal new information that undercut its claims about the origins of, and motives behind, this prosecution. Ms. Maxwell raised this issue pretrial, as required by Fed. R. Crim. P 12(b)(3)(A)(ii). In her opening memorandum Ms. Maxwell noted that significant discovery related to the allegations had not yet been provided by the government, that her investigation is ongoing, and requested that the Court defer ruling on this motion. The government’s responses to Ms. Maxwell’s motions, including its response to this motion, underscore the legitimacy of Ms. Maxwell’s continued request that the Court hold this issue open. As reflected in the various pleadings, the government did have communications with lawyers for civil litigants and did have information about the allegations made in the indictment well before it claims the investigation was opened. Ms. Maxwell learned about these things only because the government felt the need…

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