Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS THE SUPERSEDING INDICTMENT AS IT WAS OB

URT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) 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. Ever

31-7364 Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00077249 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 STATEMENT OF FACTS 2 A. Procedural History 2 B. This District's Jury Plan 2

ine Maxwell, sought and obtained an indictment of Ms. Maxwell through a grand jury drawn from the White Plains

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

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS THE SUPERSEDING INDICTMENT AS IT WAS OB

URT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) 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. Ever

lorado 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00099510 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 STATEMENT OF FACTS 2 A. Procedural History 2 B. This District's Jury Plan 2

ine Maxwell, sought and obtained an indictment of Ms. Maxwell through a grand jury drawn from the White Plains

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

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS THE SUPERSEDING INDICTMENT AS IT WAS OB

URT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) 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. Ever

olorado 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New Y rk NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00106017 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 STATEMENT OF FACTS 2 A. Procedural History 2 B. This District's Jury Plan 2

ine Maxwell, sought and obtained an indictment of Ms. Maxwell through a grand jury drawn from the White Plains

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

Dismiss_Indictment_As_Obtained_In_Violation_of Sixth _Amendment.pdf Ted, Bekah, Tom, Kristy: Attached for review please find a draft opposition to Maxwell's motion to dismiss the indictment on the ground that it was returned by a White Plains grand jury. Per Tom's request, I am including a redline with

ndictment on the ground that it was returned by a White Plains grand jury. Per Tom's request, I am including a redline with our office's briefing in Balde, so you can easily see any differences between the two. I've also attached Maxwell's motion for reference. Thanks, EFTA00106015