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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
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.
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
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.
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
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 Ghislaine Maxwell and Martin Decl

Jeffrey Epstein
PERSON
Prince Andrew
PERSONSouthern District
LOCATION
Michael Cohen
PERSONJeffrey Pagliuca
PERSONLeon Black
PERSON
Denver
LOCATIONEmmy Taylor
PERSON
Colorado
LOCATION
Christian Everdell
PERSON
Scarlett Johansson
PERSONCohen & Gresser LLP
ORGANIZATIONMark S. Cohen
PERSON
the United States District Court
ORGANIZATION
Bronx
LOCATIONthe Upper East Side
LOCATION
White Plains
LOCATION
Louisiana
LOCATIONR. Everdell
PERSONMORGAN & FOREMAN
ORGANIZATION