DOJ-OGR-00005230.jpg
751 KB
Extraction Summary
2
People
5
Organizations
1
Locations
6
Events
1
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
751 KB
Summary
This legal filing from Ms. Maxwell's defense counsel, Bobbi C. Sternheim, argues that Ms. Maxwell's right to prepare her defense has been compromised. The document details how the Government refused to hand-deliver a hard drive of evidence to the Metropolitan Detention Center (MDC), instead using FedEx, and how the MDC then delayed giving the materials to Ms. Maxwell for several days. Counsel requests the Court's intervention due to the MDC's alleged inefficiency and mishandling of legal mail.
People (2)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
The defendant in the case, who has been in custody and experienced delays in receiving evidence for her defense.
|
| Bobbi C. Sternheim | Counsel |
The attorney whose law office is named in the letterhead, representing Ms. Maxwell.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| LAW OFFICES OF BOBBI C. STERNHEIM | Law firm |
Appears in the letterhead of the document, representing the defendant.
|
| Government | Government agency |
The prosecuting party in the case, responsible for disclosing evidence.
|
| Court | Judicial body |
The entity that set the disclosure deadline and is being asked to intervene.
|
| MDC | Correctional facility |
The Metropolitan Detention Center where Ms. Maxwell is in custody and which is accused of delaying the delivery of le...
|
| FedEx | Company |
The courier service used by the Government to send a hard drive to the MDC.
|
Timeline (6 events)
2021-10-11
The Court established a deadline for the Government to disclose materials to the defense.
2021-10-11
The Government produced approximately 14,000 pages of materials to counsel.
Government
counsel
2021-10-11
Counsel requested that the Government hand-deliver a hard drive of evidence to the MDC for Ms. Maxwell.
MDC
counsel
Government
2021-10-12
2021-10-13
Counsel informed the Government that Ms. Maxwell had still not received the hard drive.
counsel
Government
2021-10-14
Locations (1)
| Location | Context |
|---|---|
|
The location where Ms. Maxwell is being held and where the hard drive of evidence was delivered.
|
Relationships (1)
The document is from the law office of Bobbi C. Sternheim and argues on behalf of 'Ms. Maxwell' and 'defense counsel'.
Key Quotes (1)
"Based on the MDC's inefficiency and mishandling of legal mail, I have no confidence MDC is capable of fulfilling its responsibilities"Source
— counsel
(Expressing a lack of faith in the correctional facility's ability to handle sensitive legal materials for the defendant.)
DOJ-OGR-00005230.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (2,222 characters)
Case 1:20-cr-00330-PAE Document 346 Filed 10/14/21 Page 2 of 3
LAW OFFICES OF BOBBI C. STERNHEIM
LAW OFFICES OF BOBBI C. STERNHEIM
counsel. They compromise her right to prepare her defense and deprive her of her constitutional right to effective assistance of counsel.
Ms. Maxwell has been in custody for over 15 months without access to the evidence the Government intends to introduce at trial. The Court established a deadline of October 11 for those and other materials to be disclosed. Late in the evening of October 11, the Government produced to counsel approximately 14,000¹ pages of single-spaced witness materials, as well as numerous exhibits and its purported 404(b) Notice and Co-Conspirator Notice. But the Government refused to hand-deliver those materials to MDC as they have with previous productions in this case. Because the MDC will not accept hard drives from defense counsel but will from the Government, counsel provided hard-drives to the Government a week in advance of October 11 and requested that it hand deliver the hard drive to MDC on October 11, the day of Court-ordered disclosure. The government denied this request, choosing instead to send the hard drive via FedEx.
Tracking information confirms that the MDC received the hard drive on October 12. On October 13, counsel informed the Government that Ms. Maxwell still had not received the hard drive and emailed MDC Legal. Again this morning, counsel emailed MDC Legal regarding the failure to provide Ms. Maxwell with the hard drive containing 3500 material. The MDC has failed to respond. Ms. Maxwell did not receive the hard drive until late this morning.
It is imperative that the Court intervene. As we approach trial, it is ever more imperative that critical trial documents and Jencks Act and Giglio material be given to Ms. Maxwell promptly upon delivery to the institution. Based on the MDC's inefficiency and mishandling of legal mail, I have no confidence MDC is capable of fulfilling its responsibilities and every reason
¹ There appear to be approximately 8,000 pages of testifying witness materials, and another 6,000 single-spaced pages of newly produced “non-testifying witness” materials, the bulk of which appears exculpatory.
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DOJ-OGR-00005230
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