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d. As a result of the COVID-19 pandemic, the government apparently chose to stop using the Manhattan Master Wheel and to indict Ms. Maxwell using a White Plains grand jury. B. This District's Jun Plan The Jury Selection and Service Act of 1968 mandates that each federal district court "devise and place in
MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS THE SUPERSEDING INDICTMENT AS IT WAS OBTAINED IN VIOLATION OF THE SIXTH AMENDMENT Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York NY 10022 Phone Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FO
Maxwell on the anniversary of Epstein's indictment and maximize the announcement's appeal to the media, the government indicted Ms. Maxwell using a White Plains grand jury, thereby violating Ms. Maxwell's right to a grand jury drawn from a fair cross-section of the community. • Finally, the government has
20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS SUPERSEDING INDICTMENT FOR BREACH OF NON-PROSECUTION AGREEMENT Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices o
d. As a result of the COVID-19 pandemic, the government apparently chose to stop using the Manhattan Master Wheel and to indict Ms. Maxwell using a White Plains grand jury. B. This District's Jun Plan The Jury Selection and Service Act of 1968 mandates that each federal district court "devise and place in
MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS THE SUPERSEDING INDICTMENT AS IT WAS OBTAINED IN VIOLATION OF THE SIXTH AMENDMENT Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADD
Maxwell on the anniversary of Epstein's indictment and maximize the announcement's appeal to the media, the government indicted Ms. Maxwell using I White Plains grand jury, thereby violating Ms. Maxwell's right to grand jury drawn from I fair cross-section of the community. • Finally, the government has cha
that Ms. Maxwell be permitted to take discovery in aid of such I hearing. Dated: January 25, 2021 New York, New York Respectfully submitted, /s/ Mark S. Cohen Attorneys for Ghislaine Maxwell 32 EFTA00099388 CERTIFICATE OF SERVICE I hereby certify that on January 25, 2021, I served by email, pursuant R
d. As a result of the COVID-19 pandemic, the government apparently chose to stop using the Manhattan Master Wheel and to indict Ms. Maxwell using a White Plains grand jury. B. This District's Jun Plan The Jury Selection and Service Act of 1968 mandates that each federal district court "devise and place in
MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS THE SUPERSEDING INDICTMENT AS IT WAS OBTAINED IN VIOLATION OF THE SIXTH AMENDMENT Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
Entities connected to both White Plains and Mark S. Cohen

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Michael Cohen
PERSONJeffrey Pagliuca
PERSONSouthern District
LOCATION
Christian Everdell
PERSONLaura Menninger
PERSON
Prince Andrew
PERSON
United States
LOCATIONCohen & Gresser LLP
ORGANIZATION
George W. Bush
PERSON
John F. Kennedy
PERSON
Denver
LOCATION
Donald Trump
PERSONthe Southern District
LOCATION
Colorado
LOCATIONSecond Circuit
ORGANIZATION
Stephen Hawking
PERSON
Virginia Giuffre
PERSON
Department of Justice
ORGANIZATION