EFTA00028968.pdf

260 KB
View Original

Extraction Summary

5
People
6
Organizations
1
Locations
1
Events
3
Relationships
4
Quotes

Document Information

Type: Legal pleading (reply memorandum)
File Size: 260 KB
Summary

This document is a Reply Memorandum filed on March 15, 2021, by Ghislaine Maxwell's defense team in the Southern District of New York. The defense argues that Counts 1 and 3 of the Superseding Indictment are multiplicitous (charging the same crime twice based on identical facts) and requests the Court order the government to elect one count to prosecute and dismiss the other prior to trial to avoid jury prejudice. The filing contends that the government has failed to prove the existence of two distinct conspiracies.

People (5)

Name Role Context
Ghislaine Maxwell Defendant
Subject of the criminal case and the motion to dismiss multiplicitous counts.
Jeffrey S. Pagliuca Attorney
Defense counsel for Ghislaine Maxwell, Haddon, Morgan & Foreman P.C.
Laura A. Menninger Attorney
Defense counsel for Ghislaine Maxwell, Haddon, Morgan & Foreman P.C.
Christian R. Everdell Attorney
Defense counsel for Ghislaine Maxwell, Cohen & Gresser LLP; signed the Certificate of Service.
Bobbi C. Sternheim Attorney
Defense counsel for Ghislaine Maxwell, Law Offices of Bobbi C. Sternheim.

Timeline (1 events)

2021-03-15
Filing of Reply Memorandum
Southern District of New York
Ghislaine Maxwell Defense Counsel

Locations (1)

Location Context

Relationships (3)

Ghislaine Maxwell Attorney-Client Jeffrey S. Pagliuca
Listed as Attorney for Ghislaine Maxwell
Ghislaine Maxwell Attorney-Client Christian R. Everdell
Listed as Attorney for Ghislaine Maxwell
Ghislaine Maxwell Attorney-Client Laura A. Menninger
Listed as Attorney for Ghislaine Maxwell

Key Quotes (4)

"The government does not dispute that Counts 1 and 3 charge Ms. Maxwell with the same crime, conspiracy in violation of 18 U.S.C. § 371, nor that the charges are based on identical facts."
Source
EFTA00028968.pdf
Quote #1
"Effectively conceding that the counts are multiplicitious, the government argues that the motion is 'premature,' focusing only on the jeopardy problem that would occur if Ms. Maxwell were convicted on both counts at trial and ignoring the prejudice to Ms. Maxwell attendant to the overcharging."
Source
EFTA00028968.pdf
Quote #2
"Ms. Maxwell has been charged with the identical conduct in Counts 1-4. These multiple counts falsely suggest to the jury that Ms. Maxwell is alleged to have committed more than one crime."
Source
EFTA00028968.pdf
Quote #3
"The defect in the Indictment is patent and prejudicial, and the Court should remove the defect by requiring the government to elect which of the conspiracy charges it will move forward with and dismiss the remaining conspiracy charge."
Source
EFTA00028968.pdf
Quote #4

Discussion 0

Sign in to join the discussion

No comments yet

Be the first to share your thoughts on this epstein document