📧 Communication

This document is page 12 of a defense filing (Document 120) from January 2021 in the case United States v. Ghislaine Maxwell. The text argues against the 'joinder' (combining) of Perjury Counts with Mann Act Counts, stating that Maxwell's alleged false statements in 2016 civil depositions were tangential to the defamation case and not part of a 'common scheme' to obstruct the Mann Act investigation. The defense distinguishes this case from legal precedent (Potamitis), emphasizing that Maxwell did not lie to the FBI or a Grand Jury to derail an investigation.