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One or Count Three as multiplicitous, (3) dismiss the S2 Indictment for pre-indictment delay, 
and (4) order the government to file a Bill of Particulars as to Counts Five and Six.' 
CONCLUSION 
For the foregoing reasons, Ms. Maxwell respectfully requests that the Court (1) dismiss 
Counts One, Three, Five, and Six of the S2 Indictment for breach of the NPA, (2) dismiss Counts 
Five and Six of the S2 Indictment for violation of Ms. Maxwell's rights under the Double 
Jeopardy Clause, (3) order the government to produce Accuser-4's prior statements as Brady 
material, and (4) grant her other requested relief. 
Dated: May 28, 2021 
New York, New York 
Respectfully submitted, 
Is/ Christian R. Everdell 
Christian R. Everdell 
COHEN & GRESSER LLP 
800 Third Avenue 
ISO 
Jeffrey S. Pagliuca 
Laura A. Menninger 
HADDON, MORGAN & FOREMAN P.C. 
150 East 10th Avenue 
Denver Colorado 80203 
Bobbi C. Sternheim 
Law Offices of Bobbi C. Sternheim 
7 Ms. Maxwell notes that her request for a Bill of Particulars includes a request that the government identify the 
other unnamed co-conspirators who allegedly participated in the conspiracy charged in Count Five with Epstein and 
Ms. Maxwell. (Mem. at 23-24). Ms. Maxwell's initial pretrial motions included a similar request for the 
conspiracies charged in Counts One and Three. (Dkt. 148-1, Ex. A). For the reasons set forth in the May 21, 2021 
joint letter to the Court, Ms. Maxwell requests that the government provide this information to the defense, along 
with any purported co-conspirator statements the government intends to offer at trial, at the same time the 
government produces Jencks Act/3500 material. (See Dkt. 291 at 10.12). 
17 
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33 West 19th Street - 4th Floor 
New York, NY 10011 
Attorneys for Ghislaine Maxwell 
18 
EFTA00104432

CERTIFICATE OF SERVICE 
I hereby certify that on May 28, 2021, I served by email, pursuant Rule 2(B) of the 
Court's individual practices in criminal cases, the within memorandum upon the following: 
MIN
=
Esq. m
/s/ Christian R. Everdell 
Christian R. Everdell 
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