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526 KB
Extraction Summary
3
People
2
Organizations
0
Locations
4
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing / court motion (defense reply regarding continuance)
File Size:
526 KB
Summary
This page is from a legal motion filed by the defense team of Ghislaine Maxwell (specifically Bobbi C. Sternheim's office) on April 19, 2021. The defense argues that the government's opposition to a trial continuance is unreasonable because the prosecution has significantly expanded the case, including increasing the conspiracy timeline from 4 to 11 years and adding new charges related to 'Accuser-4'. The document highlights a massive discovery dump on April 13, 2021, involving 20,000 pages of documents related to 226 non-testifying witnesses, which the defense claims they need more time to review before the scheduled July 12 trial.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the prosecution; defense argues they need more time to prepare for her trial.
|
| Accuser-4 | Witness/Victim |
Interviewed by the government in January 2020; allegations led to a second superseding indictment.
|
| Bobbi C. Sternheim | Defense Attorney |
Name appears on the law firm letterhead in the header.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim |
Firm representing Ms. Maxwell.
|
|
| The Government |
Department of Justice/Prosecution team opposing the continuance.
|
Timeline (4 events)
2021-04-13
Government production of 20,000 pages of material regarding 226 non-testifying witnesses.
Unknown
The Government
Defense Team
Relationships (2)
Government interviewed Accuser-4 in January 2020.
Document is filed by Law Offices of Bobbi C. Sternheim on behalf of Ms. Maxwell.
Key Quotes (4)
"The government has effectively added a brand new case on top of the existing case."Source
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Quote #1
"The government's double-standard approach is simply wrong."Source
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Quote #2
"On April 13, 2021... the government produced over 20,000 pages of interview notes, reports and other materials related to 226 separate witnesses whom the government does not intend to call as witnesses at trial."Source
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Quote #3
"We cannot adequately prepare for a trial containing the new charges and a substantially expanded conspiracy in the less than three months remaining."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,246 characters)
Case 1:20-cr-00330-AJN Document 231 Filed 04/19/21 Page 2 of 8
LAW OFFICES OF BOBBI C. STERNHEIM
LAW OFFICES OF BOBBI C. STERNHEIM
investigation in 2007 (see Dkt. 199 at 1-2), long before commencing this prosecution against Ms.
Maxwell. We cannot adequately prepare for a trial containing the new charges and a
substantially expanded conspiracy in the less than three months remaining.
Maxwell. We cannot adequately prepare for a trial containing the new charges and a
substantially expanded conspiracy in the less than three months remaining.
Government Opposition to a Continuance Is Unreasonable
The government implies that the assumptions underlying the July 12 trial date are
irrelevant because it represented, as it always does, that its investigation was “ongoing.” But
“ongoing investigation” does not imply superseding the indictment to enlarge the originally
charged conspiracy from four to eleven years and adding two new distinct charges based on
distinct alleged conduct that purportedly took place outside the time period of the original
charges. This is not a situation where the government’s “ongoing investigation” has yielded, for
example, a new overt act to an existing conspiracy. The government has effectively added a
brand new case on top of the existing case. This is a significant expansion of the case against
Ms. Maxwell that requires considerable time for the defense to investigate and prepare. Indeed,
by its own admission, the government needed more than two months after its January 2020
interview of Accuser-4 to properly investigate her allegations and obtain the second superseding
indictment. Yet, the government confidently contends that the defense will not need any
additional time to prepare to defend against this revised prosecution. The government’s double-
standard approach is simply wrong. The defense is entitled to conduct a meaningful defense
investigation and must have adequate time to do so.
irrelevant because it represented, as it always does, that its investigation was “ongoing.” But
“ongoing investigation” does not imply superseding the indictment to enlarge the originally
charged conspiracy from four to eleven years and adding two new distinct charges based on
distinct alleged conduct that purportedly took place outside the time period of the original
charges. This is not a situation where the government’s “ongoing investigation” has yielded, for
example, a new overt act to an existing conspiracy. The government has effectively added a
brand new case on top of the existing case. This is a significant expansion of the case against
Ms. Maxwell that requires considerable time for the defense to investigate and prepare. Indeed,
by its own admission, the government needed more than two months after its January 2020
interview of Accuser-4 to properly investigate her allegations and obtain the second superseding
indictment. Yet, the government confidently contends that the defense will not need any
additional time to prepare to defend against this revised prosecution. The government’s double-
standard approach is simply wrong. The defense is entitled to conduct a meaningful defense
investigation and must have adequate time to do so.
The government’s recent production of 3500 material for non-testifying witnesses
underscores the significant amount of time that the defense will need to investigate. On April 13,
2021, in a highly unusual, if not unprecedented disclosure, the government produced over 20,000
pages of interview notes, reports and other materials related to 226 separate witnesses whom the
government does not intend to call as witnesses at trial. Ms. Maxwell has not yet received these
underscores the significant amount of time that the defense will need to investigate. On April 13,
2021, in a highly unusual, if not unprecedented disclosure, the government produced over 20,000
pages of interview notes, reports and other materials related to 226 separate witnesses whom the
government does not intend to call as witnesses at trial. Ms. Maxwell has not yet received these
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DOJ-OGR-00001390
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