Federal Court Filing: Ghislaine Maxwell'S Reply In Support Of (EFTA00090721)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C. Denver Phone: Christian R. Everdell COHEN & GRESSER LLP New York NY Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Chislaine Maxwell EFTA00090721 TABLE OF CONTENTS I. A. B. C. D. THIS COURT SHOULD PRECLUDE INTRODUCTION OF ALLEGED CO- CONSPIRATOR STATEMENTS AS A SANCTION FOR GOVERNMENTS FAILURE TO COMPLY WITH THIS COURT'S SEPTEMBER 3, 2021 ORDER 1 The Court's Order was Neither Ambiguous Nor Misread by the Defense 1 The Court Has the Authority to Require Disclosure 2 There Should Be a Sanction 4 There are Substantial Issues with the Government's Anticipated Position 5 II. GOVERNMENT CONCEDEDLY FAILED TO GIVE NOTICE OF THE BASIS OR REASONING TO ADMIT ANY