GG COHEN & GRESSER LLP

GG COHEN & GRESSER LLP 1100 Thud twenue New York NY 10022 Mark S. Cohen Christian R. Eveniell +1 1212 957-7600 January 25, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) www.00hengeSSer.COM Dear Judge Nathan: On behalf of our client, Ghislaine Maxwell, we will be filing the following pretrial motions with accompanying exhibits: I. Motion to Dismiss the Superseding Indictment for Breach of the Non-Prosecution Agreement 2. Motion to Dismiss Counts One through Four of the Superseding Indictment as Time- Barred 3. Motion Under the Due Process Clause to Suppress All Evidence Obtained from the Government's Subpoena to and to Dismiss Counts Five and Six 4. Motion to Dismiss Counts Five and Six of the Superseding Indictment Because the Alleged Misstatements Are Not Penurious as a Matter of Law 5. Motion for a Severan