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B. At A Minimum, This Court Should Order A Hearing At Which Maxwell 
May Inquire Into The Circumstances Surrounding The Government's 
Misrepresentations To Judge McMahon 
If the Court is disinclined to grant relief on the present record, then at a minimum it 
should hold an evidentiary hearing to probe the government's misstatements to Judge McMahon 
and the extent to which the prosecutor's office had, in fact, coordinated with Boies Schiller prior 
to the issuance of the grand jury subpoena. These factual issues go directly to whether the 
predicate finding for Judge McMahon's ruling—namely, that no Chemical Bank collusion had 
occurred—was mistaken. See, e.g., United States v. Paredes-Cordova, No. SI 03 CR. 987DAB, 
2009 WL 1585776, at *1 (S.D.N.Y. June 8, 2009) ("An evidentiary hearing is normally required 
to address motions to suppress where a factual issue is in dispute."). 
An evidentiary hearing is warranted for an additional reason as well: If it turns out that 
the prosecutor knew (or was reckless in not knowing) that Boies Schiller had previously 
approached his office, both before and after the Maxwell depositions, in an effort to stir up a 
criminal prosecution and dangled the deposition transcripts as a carrot, then suppression would 
be warranted on that basis alone. Cf. Franks v. Delaware, 438 U.S. 154, 155-56 (1978); United 
States v. Rajaratnani, 719 F.3d 139, 146 (2d Cir. 2013) ("Franks instructs a district court to hold 
a hearing to determine whether the alleged misstatements or omissions in the warrant or wiretap 
application were made intentionally or with reckless disregard for the truth and, if so, whether 
any such misstatements or omissions were material."). 
CONCLUSION 
For these reasons, this Court should: (1) suppress all evidence the government obtained 
from Boies Schiller and any other evidence derived therefrom; or (2) suppress the April and July 
2016 depositions and all evidence derived therefrom; and (3) dismiss Counts Five and Six. 
Maxwell requests an evidentiary hearing on this Motion. 
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Dated: January 25, 2021 
Respectfully submitted, 
s/ Jeffrey S. Pagliuca 
Jeffrey S. Pagliuca 
Laura A. Menninger 
HADDON, MORGAN & FOREMAN P.C. 
150 East 10th Avenue 
Denver CO 80203 
Phone: 
Mark S. Cohen 
Christian R. Everdell 
COHEN & GRESSER LLP 
00 Third Avenue New York, NY 10022 Phone: 
Bobbi C. Stemheim 
Law Offices of Bobbi C. Stemheim 
33 West 19th Street - 4th Floor 
New York NY 10011 
Phone: 
Attorneys for Chislaine Maxwell 
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Certificate of Service 
I hereby certify that on January 25, 2021, served by email, pursuant Rule 2(B) of the 
Court's individual practices in criminal cases, the Memorandum of Ghislaine Maxwell in Support 
of Her Motion Under the Due Process Clause to Suppress All Evidence Obtained from the 
Government's Subpoena to Boies Schiller and to Dismiss Counts Five And Six upon the 
following: 
U.S. Attorney's Office, SDNY 
New York NY 10007 
s/ Christian R. Everdell 
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EFTA00086680