213.pdf

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pdf

Source set

house-oversight-doj

Pages

8

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Searchable text available

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0.9309035913224761

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Extracted text

Case 1:20-cr-00330-PAE Document 213 Filed 04/16/21 Page1of8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, 20 Cr. 330 (AJN) Vv. GHISLAINE MAXWELL, Defendant. REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION TO DISMISS COUNTS ONE THROUGH FOUR OF THE SUPERSEDING INDICTMENT FOR LACK OF SPECIFICITY 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-00003833 

Case 1:20-cr-00330-PAE Document 213 Filed 04/16/21 Page2of8 The government continues to stonewall Ms. Maxwell’s requests for clarity about what it claims she did to justify her continued incarceration and prosecution. Although the government has dumped thousands of pages of irrelevant discovery from inapplicable time periods on Ms. Maxwell and her counsel, it refuses to provide the most basic information about the allegations in Counts One through Four: who, what, when, and how. Because Counts One through Four of the superseding indictment (“Indictment”) lack the basic factual information necessary for Ms. Maxwell to prepare her defense, and the government refuses to provide any meaningful discovery, the Court should either dismiss these counts or direct the government to answer Ms. Maxwell’s requests for particularity. I. The Indictment Lacks the Necessary Specificity The government attempts to justify some of the Indictment’s deficiencies, e.g., lack of names and dates, through citation to obviously inapplicable cases. “First,” the government offers United States v. Stringer, 730 F.3d 120, 124 (2d Cir. 2013), for the proposition that “the use of pseudonyms to refer to minor victims of the charged conduct does not warrant dismissal…

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