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Case 22-1426, Document 59, 02/28/2023, 3475902, Page102 of 113 count (whether it be Count Four or Six). Accordingly, a new trial on the remaining count would be required. For the Reasons Stated in Points I and II, the Convictions Should Be Vacated and the Indictment Dismissed. For the Reasons Stated in Points III and IV, the Convictions should be Vacated and the Matter Remanded for a New Trial. For the Reasons Stated in Point V, the Court Should Remand To the District Court for Resentencing. Dated: New York, New York February 28, 2023 Respectfully Submitted, /s/Diana Fabi Samson ARTHUR L. AIDALA DIANA FABI SAMSON JOHN M. LEVENTHAL AIDALA, BERTUNA & KAMINS, PC Attorneys for Defendant-Appellant Ghislaine Maxwell 546 Fifth Avenue, Sixth Floor New York, New York 10036 212 486-0011 87 DOJ-OGR-00021149