DOJ-OGR-00005255.jpg
737 KB
Extraction Summary
4
People
3
Organizations
4
Locations
1
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
737 KB
Summary
This document is a letter dated October 18, 2021, from defense attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. Sternheim argues for the necessity of individual, sequestered, and counsel-conducted voir dire (jury selection), citing the extraordinary public exposure of the case, evidenced by millions of Google search results for Maxwell and Jeffrey Epstein. The letter contends that this special procedure is required to eliminate biased jurors and ensure a fair trial, countering the government's standard opposition to such methods.
People (4)
| Name | Role | Context |
|---|---|---|
| BOBBI C. STERNHEIM | Attorney |
Author of the letter, representing the defense in the case of United States v. Ghislaine Maxwell.
|
| Alison J. Nathan | United States District Judge |
Recipient of the letter, presiding over the case.
|
| Ghislaine Maxwell | Defendant |
The defendant in the case referenced, United States v. Ghislaine Maxwell.
|
| Jeffrey Epstein |
Mentioned in the context of Google search results to illustrate the high-profile nature of the case.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| LAW OFFICES OF BOBBI C. STERNHEIM | law firm |
The law firm sending the letter, as indicated in the letterhead.
|
| United States District Court | government agency |
The court where Judge Alison J. Nathan presides, also referred to as SDNY (Southern District of New York).
|
| company |
Mentioned as the source for search results regarding Ghislaine Maxwell and Jeffrey Epstein.
|
Timeline (1 events)
2021-10-18
Defense counsel Bobbi C. Sternheim filed a letter with the court arguing for individual sequestered voir dire in the jury selection process for the Ghislaine Maxwell trial.
United States District Court, Southern District of New York
Locations (4)
| Location | Context |
|---|---|
|
The address of the Law Offices of Bobbi C. Sternheim.
|
|
|
The address of the United States Courthouse where Judge Nathan is located.
|
|
|
The city where both the law office and the courthouse are located.
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|
|
Abbreviation for the Southern District of New York, mentioned as having a 'standard operating procedure' regarding vo...
|
Relationships (3)
Bobbi C. Sternheim is writing as counsel for the defense in the case of United States v. Ghislaine Maxwell, indicating an attorney-client relationship.
Sternheim, an attorney, is addressing a formal letter to Judge Nathan, who is presiding over her client's case.
Their names are listed together with their Google search result counts to demonstrate the high-profile nature of the case, implying a well-known public association.
Key Quotes (3)
"We don’t do that here."Source
— The government / SDNY (as characterized by Bobbi C. Sternheim)
(Described as the 'standard SDNY operating procedure' and the government's response to requests for attorney-conducted voir dire.)
DOJ-OGR-00005255.jpg
Quote #1
"about 4,740,000 (about 0.89 seconds)"Source
— Google search results
(The number of search results for 'Ghislaine Maxwell' used as evidence of the case's high public exposure.)
DOJ-OGR-00005255.jpg
Quote #2
"about 26,200,000 results (0.86 seconds)"Source
— Google search results
(The number of search results for 'Jeffrey Epstein' used as evidence of the case's high public exposure.)
DOJ-OGR-00005255.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,093 characters)
Case 1:20-cr-00330-AJN Document 356 Filed 10/18/21 Page 1 of 1
LAW OFFICES OF BOBBI C. STERNHEIM
LAW OFFICES OF BOBBI C. STERNHEIM
212-243-1100 • Main
917-912-9698 • Cell
888-587-4737 • Fax
917-912-9698 • Cell
888-587-4737 • Fax
225 Broadway, Suite 715
New York, NY 10007
bcsternheim@mac.com
New York, NY 10007
bcsternheim@mac.com
October 18, 2021
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
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)
S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
There is nothing surprising about the government’s opposition to limited attorney-conducted voir dire and individual sequestered voir dire. (Dkt. 355.) The government’s response is standard SDNY operating procedure: “We don’t do that here.” Rarely is there an AUSA who has ever conducted voir dire, so it is easy to just say “no.” In this case, counsel are better positioned to address particular areas of case-related bias than is the Court, and requesting a mere minute per juror is far from onerous.
The proposed questionnaire seeks highly sensitive and personal information regarding each juror. Simply asking jurors to raise their hand in response to an invitation to speak privately on a personal topic is revealing and invasive. One would hope that the government would be sensitive to that fact and would want to ensure that a fair and impartial jury will be seated in this high-profile case. With each passing day, the amount of public exposure this case receives erodes that possibility. Below are today’s Google search results:
■ Ghislaine Maxwell: “about 4,740,000 (about 0.89 seconds)”
■ Jeffrey Epstein: “about 26,200,000 results (0.86 seconds)”
■ Jeffrey Epstein: “about 26,200,000 results (0.86 seconds)”
The Court has the power and the obligation to ensure that jury selection eliminates jurors who are biased and/or motivated to serve for reasons beyond being fair and impartial.
This is an extraordinary case involving sensitive issues. We urge the Court to exercise its supervisory powers and discretion and grant the defense request for individual sequestered voir dire and very limited counsel-conducted voir dire.
Very truly yours,
/s/
BOBBI C. STERNHEIM
/s/
BOBBI C. STERNHEIM
cc: All Counsel
DOJ-OGR-00005255
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