{
  "document_metadata": {
    "page_number": "1",
    "document_number": "166",
    "date": "03/15/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 166 Filed 03/15/21 Page 1 of 2\nCOHEN & GRESSER LLP\nMark S. Cohen\nChristian R. Everdell\n+1 (212) 957-7600\nmcohen@cohengresser.com\nceverdell@cohengresser.com\n800 Third Avenue\nNew York, NY 10022\n+1 212 957 7600 phone\nwww.cohengresser.com\nMarch 15, 2021\nVIA ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, New York 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nOn behalf of our client, Ghislaine Maxwell, we will be filing the following reply memoranda with accompanying exhibits:\n1. Reply Memorandum in Support of Motion to Dismiss the Superseding Indictment for Breach of the Non-Prosecution Agreement\n2. Reply Memorandum in Support of Motion to Dismiss Counts One through Four of the Superseding Indictment as Time-Barred\n3. Reply Memorandum in Support of Motion Under the Due Process Clause to Suppress All Evidence Obtained from the Government's Subpoena to [REDACTED] and to Dismiss Counts Five and Six\n4. 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\n5. Reply Memorandum in Support of Motion for a Severance of and Separate Trial on Counts Five and Six of the Superseding Indictment\n6. Reply Memorandum in Support of Motion to Strike Surplusage from the Superseding Indictment\n7. Reply Memorandum in Support of Motion to Dismiss Counts One Through Six of the Superseding Indictment for Pre-Indictment Delay\n8. Reply Memorandum in Support of Motion to Dismiss Either Count One or Count Three of the Superseding Indictment as Multiplicitous\n9. Reply Memorandum in Support of Motion to Dismiss the Superseding Indictment as It Was Obtained in Violation of the Sixth Amendment\n10. Reply Memorandum in Support of Motion for a Bill of Particulars and Pretrial Disclosures\nDOJ-OGR-00002759",
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      "content": "Case 1:20-cr-00330-AJN Document 166 Filed 03/15/21 Page 1 of 2",
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      "content": "COHEN & GRESSER LLP",
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    {
      "type": "printed",
      "content": "Mark S. Cohen\nChristian R. Everdell\n+1 (212) 957-7600\nmcohen@cohengresser.com\nceverdell@cohengresser.com",
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    {
      "type": "printed",
      "content": "800 Third Avenue\nNew York, NY 10022\n+1 212 957 7600 phone\nwww.cohengresser.com",
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    {
      "type": "printed",
      "content": "March 15, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "VIA ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, New York 10007",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "On behalf of our client, Ghislaine Maxwell, we will be filing the following reply memoranda with accompanying exhibits:",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "1. Reply Memorandum in Support of Motion to Dismiss the Superseding Indictment for Breach of the Non-Prosecution Agreement\n2. Reply Memorandum in Support of Motion to Dismiss Counts One through Four of the Superseding Indictment as Time-Barred\n3. Reply Memorandum in Support of Motion Under the Due Process Clause to Suppress All Evidence Obtained from the Government's Subpoena to [REDACTED] and to Dismiss Counts Five and Six\n4. 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\n5. Reply Memorandum in Support of Motion for a Severance of and Separate Trial on Counts Five and Six of the Superseding Indictment\n6. Reply Memorandum in Support of Motion to Strike Surplusage from the Superseding Indictment\n7. Reply Memorandum in Support of Motion to Dismiss Counts One Through Six of the Superseding Indictment for Pre-Indictment Delay\n8. Reply Memorandum in Support of Motion to Dismiss Either Count One or Count Three of the Superseding Indictment as Multiplicitous\n9. Reply Memorandum in Support of Motion to Dismiss the Superseding Indictment as It Was Obtained in Violation of the Sixth Amendment\n10. Reply Memorandum in Support of Motion for a Bill of Particulars and Pretrial Disclosures",
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  ],
  "entities": {
    "people": [
      "Mark S. Cohen",
      "Christian R. Everdell",
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "COHEN & GRESSER LLP",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "New York",
      "New York 10022",
      "New York 10007"
    ],
    "dates": [
      "March 15, 2021",
      "03/15/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 166",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00002759"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a redacted section in the third reply memorandum."
}