EFTA00028963.pdf

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pdf

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
x 
UNITED STATES OF AMERICA, 
v. 
GHISLAINE MAXWELL, 
Defendant. 
x 
20 Cr. 330 (MN) 
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. 
Christian R. Everdell 
COHEN & GRESSER LLP 
Bobbi C. Stemheim 
Law Offices of Bobbi C. Stemheim 
Attorneys for Ghislaine Maxwell 
EFTA00028963


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 to make partial disclosures in an attempt to defend its 
actions. 
In its response to the instant motion, the government, without actually disclosing the 
witness's statements, selectively "proffers" "facts" to justify its position but tells Ms. Maxwell 
and the Court that we…

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