📧 Communication

This document is page 4 of a legal filing addressed to Judge Alison J. Nathan dated December 27, 2021, during the trial of Ghislaine Maxwell. The defense argues that the jury appears to be considering convicting Maxwell on Count Four based on events in New Mexico involving a victim named 'Jane,' whereas the indictment specified events in New York. The defense contends that allowing a conviction based on the New Mexico evidence would constitute a 'constructive amendment' or 'substantial variance' from the indictment, which would be a reversible legal error.