Epstein Secrets

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

greement that its own agents negotiated and agreed to with the approval of senior levels of Main Justice. • The government has concocted a federal Mann Act case against Ms. Maxwell by alleging that, on some unspecified occasion during a four-year period between 1994 and 1997, and in an unspecified mann

MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO STRIKE SURPLUSAGE FROM SUPERSEDING INDICTMENT 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

with Jeffrey Epstein that would violate N.Y. Penal Law § 130.55. Indictment¶¶ 13, 19. The indictment does not charge Ms. Maxwell with a substantive Mann Act violation as to any individual other than Accuser-1, nor does it allege that Ms. Maxwell personally enticed or caused any person other than Accuser-

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

greement that its own agents negotiated and agreed to with the approval of senior levels of Main Justice. • The government has concocted I federal Mann Act case against Ms. Maxwell by alleging that, on some unspecified occasion during I four-year period between 1994 and 1997, and in an unspecified mann