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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
Declaration of Jeffrey Martin in Support of Motion to Dismiss, U.S v. Balde, No. 1:20-cr-00281-KPF, Dkt. No. 61-1 (filed Nov. 9, 2020), Exhibit 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.
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
Declaration of Jeffrey Martin in Support of Motion to Dismiss, U.S v. Balde, No. 1:20-cr-00281-KPF, Dkt. No. 61-1 (filed Nov. 9, 2020), Exhibit 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.
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 &
Declaration of Jeffrey Martin in Support of Motion to Dismiss, U.S v. Balde, No. 1:20-cr-00281-KPF, Dkt. No. 61-1 (filed Nov. 9, 2020), Exhibit 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.
Entities connected to both Mark S. Cohen and Martin Decl

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