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651 KB

Extraction Summary

5
People
3
Organizations
3
Locations
2
Events
2
Relationships
3
Quotes

Document Information

Type: Legal correspondence / court filing
File Size: 651 KB
Summary

This document is a legal letter dated April 15, 2021, from defense attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. Sternheim requests a continuance of the July 12th trial, arguing that a new superseding indictment significantly expands the scope of the case from a four-year period in the 1990s to an eleven-year period (1994-2004). The letter claims the government is responsible for the delay by filing late charges based on a witness known to them since the Florida investigation.

People (5)

Name Role Context
Bobbi C. Sternheim Defense Attorney
Author of the letter representing Ghislaine Maxwell.
Alison J. Nathan United States District Judge
Recipient of the letter, presiding over the case.
Ghislaine Maxwell Defendant
Subject of the criminal case (United States v. Ghislaine Maxwell).
Unnamed Witness Witness
A witness known to the government since the Florida investigation, basis for the superseding indictment.
Three Accusers Accusers
Referenced as the original accusers from the 1990s in the original indictment.

Organizations (3)

Name Type Context
Law Offices of Bobbi C. Sternheim
Legal firm representing the defendant.
United States District Court
Southern District of New York (implied by address/judge).
Department of Justice (DOJ)
Referenced in footer stamp DOJ-OGR.

Timeline (2 events)

1994-2004
Expanded relevant time period for charges in the superseding indictment.
N/A
2021-07-12
Scheduled trial date mentioned in the letter.
New York, NY

Locations (3)

Location Context
Location related to a witness known to the government.

Relationships (2)

Bobbi C. Sternheim Attorney-Client Ghislaine Maxwell
Sternheim is writing the defense letter on behalf of Maxwell.
Alison J. Nathan Judge-Defendant Ghislaine Maxwell
Nathan is the judge presiding over Maxwell's case.

Key Quotes (3)

"The recently filed superseding indictment directly contravenes that agreement and adds two new charges which vastly expand the relevant time period from a four-year period in the 1990s to an eleven-year period stretching from 1994 to 2004."
Source
DOJ-OGR-00002925.jpg
Quote #1
"We do not want to postpone the trial but have no choice but to ask for a continuance."
Source
DOJ-OGR-00002925.jpg
Quote #2
"The government bears responsibility for this need, having filed a late-breaking superseding indictment based on a witness who has been known to the government since the Florida"
Source
DOJ-OGR-00002925.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (1,832 characters)

Case 1:20-cr-00330-AJN Document 202 Filed 04/15/21 Page 1 of 8
LAW OFFICES OF BOBBI C. STERNHEIM
212-243-1100 • Main
917-306-6666 • Cell
888-587-4737 • Fax
33 West 19th Street - 4th Floor
New York, New York 10011
bc@sternheimlaw.com
April 15, 2021
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell
S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
We write in reply to the government’s April 9th letter opposing a trial continuance.
The defense has been steadfastly and diligently preparing for a July 12th trial based on the
original indictment, a date set on the condition that there would be no superseding indictment
adding substantive charges. The recently filed superseding indictment directly contravenes that
agreement and adds two new charges which vastly expand the relevant time period from a four-
year period in the 1990s to an eleven-year period stretching from 1994 to 2004. These additions
significantly alter the scope of the government’s case and necessarily shift the focus of the
defense’s trial preparation. Instead of being focused on mounting a defense to the allegations of
the three accusers from the 1990s, as we have been doing, the defense will now have to spend
considerable time and resources investigating allegations of new conduct in a completely
different time period involving numerous additional witnesses, and with all of the difficulties that
COVID restrictions still place on a meaningful defense investigation.
We do not want to postpone the trial but have no choice but to ask for a continuance. The
government bears responsibility for this need, having filed a late-breaking superseding
indictment based on a witness who has been known to the government since the Florida
DOJ-OGR-00002925

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