COHEN & GRESSER LLP

GG COHEN & GRESSER LLP Mark S. Cohen Christian R Fverdell March 15, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: On behalf of our client, Ghislaine Maxwell, we will be filing the following reply memoranda with accompanying exhibits: 1. Reply Memorandum in Support of Motion to Dismiss the Superseding Indictment for Breach of the Non-Prosecution Agreement 2. Reply Memorandum in Support of Motion to Dismiss Counts One through Four of the Superseding Indictment as Time-Barred 3. Reply Memorandum in Support of Motion Under the Due Process Clause to Suppress All Evidence Obtained from the Government's Subpoena to and to Dismiss Counts Five and Six 4. Reply Memorandum in Support of Motion to Dismiss Counts Five and Six of the Superseding Indictment Because the Alleged Misstatements Are Not Perjurious as a Matter of Law 5. Reply Memorandum