EFTA00028925.pdf

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GG
COHEN & GRESSER LLP 
Mark S. Cohen 
Christian R Fverdell 
March 15, 2021 
VIA ECF 
The Honorable Alison J. Nathan 
United States District Court 
Southern District of New York 
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) 
Dear Judge Nathan: 
On behalf of our client, Ghislaine Maxwell, we will be filing the following reply 
memoranda with accompanying exhibits: 
I. 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 Boies Schiller 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 
EFTA00028925


The Honorable Alison J. Nathan 
March 15, 2021 
Page 2 
II. Reply Memorandum in Support of Motion Under the Fourth Amendment, Martindell, 
and the Fifth Amendment to Suppress All Evidence Obtained from the Government's 
Subpoena to Boies Schiller and to Dismiss Co…
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