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Case 1:20-cr-00330-PAE Document224 Filed 04/20/21 Page15of17 one or more of Ms. Maxwell’s lawyers should become actual witnesses, a circumstance that would create a circus, not a fair trial. The truth of the matter is simple: the government included the Perjury Counts because it wants to call Ms. Maxwell a liar in front of the jury and because it wanted a way to introduce unrelated, but extremely prejudicial evidence of alleged sexual abuse through the back door. The simple, non-prejudicial, solution is to sever the Perjury Counts.’ CONCLUSION The Perjury Counts are improperly joined with the Mann Act Counts. A joint trial of these charges would deny Ms. Maxwell her right to a fair trial and her counsel. Accordingly, the Court should grant the request for a separate trial on the Perjury Counts. Dated: March 15, 2021 Respectfully submitted, s/ Jeffrey S. Pagliuca 7 Ms. Maxwell’s Colorado Counsel would not participate as advocates in any trial of those charges but would testify as witnesses. i DOJ-OGR-00003912