Case 1:20-cr-00330-AJN Document 166 Filed 03/15/21 Page 1 of 2 800 Third Avenue New York, NY 10022 COHEN & GRESSER LLP +1 212.957 7600 phone www.cohengresser.com Mark S. Cohen Christian R. Everdell +1 (212) 957-7600 [email protected] [email protected] March 15, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York AO Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: On behalf of our client, Ghislaine Maxwell, we will be filing the following reply memoranda with accompanying exhibits: 1. 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 a 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 DOJ-OGR-00002759