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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
A ("Martin Decl."). Because the jury wheels are emptied and refilled only every four years, following a presidential election, and the defendant in Balde, like Ms. Maxwell, was indicted in June 2020, Ms. Maxwell's grand jury was presumably drawn from the same wheels Mr. Martin analyzed. Mr. Martin fo
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
A ("Martin Decl."). Because the jury wheels are emptied and refilled only every four years, following a presidential election, and the defendant in Balde, like Ms. Maxwell, was indicted in June 2020, Ms. Maxwell's grand jury was presumably drawn from the same wheels Mr. Martin analyzed. Mr. Martin fo
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 &
A ("Martin Decl."). Because the jury wheels are emptied and refilled only every four years, following a presidential election, and the defendant in Balde, like Ms. Maxwell, was indicted in June 2020, Ms. Maxwell's grand jury was presumably drawn from the same wheels Mr. Martin analyzed. Mr. Martin fo
Entities connected to both Mark S. Cohen and Balde

Michael Cohen
PERSON
Ghislaine Maxwell
PERSONJeffrey Pagliuca
PERSON
Christian Everdell
PERSON
Jeffrey Epstein
PERSONCohen & Gresser LLP
ORGANIZATIONSouthern District
LOCATION
Prince Andrew
PERSONR. Everdell
PERSON
Denver
LOCATION
Colorado
LOCATIONMORGAN & FOREMAN
ORGANIZATIONBobbi C. Stemheim
PERSON
White Plains
LOCATION
the United States District Court
ORGANIZATIONLeon Black
PERSON
Louisiana
LOCATION
Scarlett Johansson
PERSONEmmy Taylor
PERSONReyes
PERSON