DOJ-OGR-00002820.pdf

--- Page 1 --- **Document Header** * Case Number: 1:20-cr-00330-PAE * Document Number: 185 * Filed Date: 03/26/21 * Page Number: 1 of 2 **U.S. Department of Justice** * United States Attorney * Southern District of New York **Address** * The Silvio J. Mollo Building * One Saint Andrew's Plaza * New York, New York 10007 **Date** * March 26, 2021 **BY ECF** * The Honorable Alison J. Nathan * United States District Judge * Southern District of New York * 40 Foley Square * New York, New York 10007 **Re:** * United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) **Dear Judge Nathan:** * The Government respectfully writes to bring the Court’s attention to a recent decision by Judge Crotty in United States v. Schulte, 17 Cr. 548 (PAC), which is attached hereto as Exhibit 1 (“Schulte Op.”). In that case, the defendant filed a motion to dismiss the indictment on November 16, 2020 (see 17 Cr. 548 (PAC), ECF No. 435), which was virtually identical in multiple respects to the January 25, 2021 motion to dismiss the indictment filed by defendant Ghislaine Maxwell in the above-captioned case (see 20 Cr. 330 (AJN), ECF No. 126). Like Maxwell, the defendant in Schulte asserted, among other things, a claim under the Sixth Amendment of the Constitution, arguing that the indictment should be dismissed because the grand jury sitting in White Plains unfairly underrepresented Black and Hispanic individuals. Judge Crotty rejected those claims in their entirety and denied the defendant’s motion to dismiss. Judge Crotty’s thorough, well-reasoned decision supports the Government’s position in this case. **DOJ-OGR-00002820**