📧 Communication

This document is a Reply Memorandum filed by Ghislaine Maxwell's defense team on March 15, 2021, supporting a motion to dismiss counts 1-4 of the superseding indictment. The defense argues that the indictment lacks specificity regarding names, dates, and details of the allegations, preventing Maxwell from preparing an adequate defense. The filing criticizes the government for using vague categories like 'Minor Victims' and 'multiple minor girls' without clarification and cites legal precedents to argue that the lack of specificity violates due process.