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Case 1:20-cr-00330-AJN Document 124 Filed 01/25/21 Page 7 of 8 non-criminal acts of so-called “grooming” (talking to or being nice to someone, or taking them to a movie), it is impossible to know what act or acts she needs to defend against at trial. CONCLUSION Neither the Indictment nor the discovery provide Ms. Maxwell with enough information so that she can prepare her defense as to Counts One through Four, and these Counts should be dismissed for a lack of specificity in violation of the Fifth and Sixth Amendments to the United States Constitution. Alternatively, the Court should direct the government to provide Ms. Maxwell with a Bill of Particulars and discovery as requested in her contemporaneously filed Memorandum in Support of Motion for Bill of Particulars and Pretrial Disclosures. Dated: January 25, 2021 Respectfully submitted, s/ Jeffrey S. Pagliuca Jeffrey S. Pagliuca (pro hac vice) Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell DOJ-OGR-00002317