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Case 1:20-cr-00330-AJN Document 118 Filed 01/25/21 Page 1 of 2 800 Third Avenue New York, NY 10022 COHEN & GRESSER LLP +1 212.957 7600 phone www.cohengresser.com Mark S. Cohen Christian R. Everdell +1 (212) 957-7600 mcohen@cohengresset.com cevetdell@cohengtesset.com January 25, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: On behalf of our client, Ghislaine Maxwell, we will be filing the following pretrial motions with accompanying exhibits: 1. Motion to Dismiss the Superseding Indictment for Breach of the Non-Prosecution Agreement 2. Motion to Dismiss Counts One through Four of the Superseding Indictment as Time- Barred 3. Motion Under the Due Process Clause to Suppress All Evidence Obtained from the Government’s Subpoena to ee and to Dismiss Counts Five and Six 4. Motion to Dismiss Counts Five and Six of the Superseding Indictment Because the Alleged Misstatements Are Not Perjurious as a Matter of Law 5. Motion for a Severance of and Separate Trial on Counts Five and Six of the Superseding Indictment 6. Motion to Strike Surplusage from the Superseding Indictment 7. Motion to Dismiss Counts One Through Six of the Superseding Indictment for Pre- Indictment Delay 8. Motion to Dismiss Either Count One or Count Three of the Superseding Indictment as Multiplicitous 9. Motion to Dismiss the Superseding Indictment as It Was Obtained in Violation of the Sixth Amendment 10. Motion for a Bill of Particulars and Pretrial Disclosures 11. Motion Under the Fourth Amendment, Martindell, and the Fifth Amendment to Suppress All Evidence Obtained from the Government’s Subpoena to and to Dismiss Counts Five and Six 12. Motion to Dismiss Counts One through Four of the Superseding Indictment for Lack of Specificity DOJ-OGR-00002275