EFTA00028974.pdf

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pdf

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data-set-8

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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 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. 
Christian R. Everdell 
COHEN & GRESSER LLP 
Bobbi C. Stemheim 
Law Offices of Bobbi C. Stemheim 
Attorneys for Ghislaine Maxwell 
EFTA00028974


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 of the indictment." Resp. at 153. The government fails to 
point out, however, that Stringer was a fraud case in which the conduct was alleged to have 
occurred over a 7-month period. The indictment was brought within a few years, not decades, of 
the alleged crime, and the…

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