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521 KB

Extraction Summary

7
People
6
Organizations
6
Locations
1
Events
5
Relationships
1
Quotes

Document Information

Type: Legal document
File Size: 521 KB
Summary

This document is the conclusion of a legal filing dated January 25, 2021, submitted by the attorneys for Ghislaine Maxwell. The attorneys argue that the indictment lacks the necessary specificity for Maxwell to prepare an adequate defense for Counts One through Four, violating her Fifth and Sixth Amendment rights. They request that the court either dismiss these counts or compel the government to provide a Bill of Particulars and further discovery.

People (7)

Name Role Context
Ms. Maxwell Defendant
Referenced as the individual for whom the legal motion is being filed, arguing she lacks sufficient information to pr...
Jeffrey S. Pagliuca Attorney
Listed as one of the attorneys for Ghislaine Maxwell, submitting the document.
Laura A. Menninger Attorney
Listed as one of the attorneys for Ghislaine Maxwell.
Mark S. Cohen Attorney
Listed as one of the attorneys for Ghislaine Maxwell.
Christian R. Everdell Attorney
Listed as one of the attorneys for Ghislaine Maxwell.
Bobbi C. Sternheim Attorney
Listed as one of the attorneys for Ghislaine Maxwell.
Ghislaine Maxwell Defendant
Identified as the client for whom the attorneys are acting.

Organizations (6)

Name Type Context
HADDON, MORGAN & FOREMAN P.C. Law firm
Law firm representing Ghislaine Maxwell, employing attorneys Jeffrey S. Pagliuca and Laura A. Menninger.
COHEN & GRESSER LLP Law firm
Law firm representing Ghislaine Maxwell, employing attorneys Mark S. Cohen and Christian R. Everdell.
Law Offices of Bobbi C. Sternheim Law firm
Law firm representing Ghislaine Maxwell, run by Bobbi C. Sternheim.
United States Constitution Government document
Cited in the argument that the indictment violates the Fifth and Sixth Amendments.
The Court Government agency
The judicial body being asked to either dismiss counts or direct the government to provide more information.
The government Government agency
The prosecuting party, which the defense requests be directed to provide a Bill of Particulars.

Timeline (1 events)

2021-01-25
A legal memorandum was filed on behalf of Ghislaine Maxwell, arguing for the dismissal of charges or for the provision of a Bill of Particulars.

Locations (6)

Location Context
Address for the law firm HADDON, MORGAN & FOREMAN P.C.
Location of the law firm HADDON, MORGAN & FOREMAN P.C.
Address for the law firm COHEN & GRESSER LLP.
Location of the law firms COHEN & GRESSER LLP and Law Offices of Bobbi C. Sternheim.
Address for the Law Offices of Bobbi C. Sternheim.
Mentioned in reference to the United States Constitution.

Relationships (5)

Ghislaine Maxwell Attorney-Client Jeffrey S. Pagliuca
The document states Jeffrey S. Pagliuca is one of the 'Attorneys for Ghislaine Maxwell'.
Ghislaine Maxwell Attorney-Client Laura A. Menninger
Laura A. Menninger is listed under a law firm identified as 'Attorneys for Ghislaine Maxwell'.
Ghislaine Maxwell Attorney-Client Mark S. Cohen
Mark S. Cohen is listed under a law firm identified as 'Attorneys for Ghislaine Maxwell'.
Ghislaine Maxwell Attorney-Client Christian R. Everdell
Christian R. Everdell is listed under a law firm identified as 'Attorneys for Ghislaine Maxwell'.
Ghislaine Maxwell Attorney-Client Bobbi C. Sternheim
Bobbi C. Sternheim is listed under a law firm identified as 'Attorneys for Ghislaine Maxwell'.

Key Quotes (1)

"Neither the Indictment nor the discovery provide Ms. Maxwell with enough information so that she can prepare her defense as to Counts One through Four, and these Counts should be dismissed for a lack of specificity in violation of the Fifth and Sixth Amendments to the United States Constitution."
Source
— Attorneys for Ghislaine Maxwell (This is the core argument presented in the conclusion of the legal filing, requesting dismissal of charges.)
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Quote #1

Full Extracted Text

Complete text extracted from the document (1,313 characters)

Case 1:20-cr-00330-AJN Document 124 Filed 01/25/21 Page 7 of 8
non-criminal acts of so-called “grooming” (talking to or being nice to someone, or taking them to a movie), it is impossible to know what act or acts she needs to defend against at trial.
CONCLUSION
Neither the Indictment nor the discovery provide Ms. Maxwell with enough information so that she can prepare her defense as to Counts One through Four, and these Counts should be dismissed for a lack of specificity in violation of the Fifth and Sixth Amendments to the United States Constitution. Alternatively, the Court should direct the government to provide Ms. Maxwell with a Bill of Particulars and discovery as requested in her contemporaneously filed Memorandum in Support of Motion for Bill of Particulars and Pretrial Disclosures.
Dated: January 25, 2021
Respectfully submitted,
s/ Jeffrey S. Pagliuca
Jeffrey S. Pagliuca (pro hac vice)
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303-831-7364
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Phone: 212-957-7600
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Phone: 212-243-1100
Attorneys for Ghislaine Maxwell
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DOJ-OGR-00002317

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