DOJ-OGR-00001392.jpg
519 KB
Extraction Summary
3
People
2
Organizations
0
Locations
2
Events
2
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
519 KB
Summary
This legal document, filed by the Law Offices of Bobbi C. Sternheim on behalf of their client Ms. Maxwell, details the significant challenges the defense faces in reviewing a massive amount of discovery evidence. The defense argues that new charges, the addition of 'Accuser-4', and the sheer volume of materials (including 214,000 photos and 250,000 non-searchable documents) necessitate a lengthy re-review process. The document also mentions technical difficulties with an FBI-supplied laptop, further complicating and delaying their review of 'Highly Confidential' photographs.
People (3)
| Name | Role | Context |
|---|---|---|
| BOBBI C. STERNHEIM | Attorney |
Appears in the header as the name of the law office filing the document.
|
| Ms. Maxwell | Defendant |
Mentioned as the individual for whom the defense is working and who needs to review evidence like photographs and vid...
|
| Accuser-4 | Accuser |
Mentioned as a new addition to the case, necessitating a re-review of discovery materials.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| LAW OFFICES OF BOBBI C. STERNHEIM | Law firm |
Appears in the header of the document, indicating it is the source of the filing.
|
| FBI | Government agency |
Mentioned as the supplier of a laptop and hard drive used by the defense to review evidence.
|
Timeline (2 events)
Defense counsel conducted an evidence view with Ms. Maxwell over the past three days to review photographs.
Ms. Maxwell
defense counsel
The filing of a superseding indictment and the addition of Accuser-4, which expanded the scope of the charges and the required discovery review.
The government
The defense
Relationships (2)
The document is from the Law Offices of Bobbi C. Sternheim and discusses the defense strategy and challenges for their client, Ms. Maxwell.
The document states that the addition of 'Accuser-4' to the case has forced the defense to re-review a large volume of evidence.
Full Extracted Text
Complete text extracted from the document (2,197 characters)
Case 1:20-cr-00330-AJN Document 57 Filed 04/19/2021 Page 4 of 8
LAW OFFICES OF BOBBI C. STERNHEIM
The defense has tried to streamline its review of the discovery even before the filing of
superseding indictment by using term searches and key word searches. But given the nature of
the discovery, there are meaningful limits to what the defense can do to limit the number of
documents it must re-review in light of the new charges. For example, the discovery contains
approximately 214,000 photographs, hundreds of hours of audio-visual files, and over 250,000
documents where the text is too poor to be OCR-searchable. Those materials are not susceptible
to text searching and must be reviewed individually. Moreover, they must be reviewed with Ms.
Maxwell to see if she recognizes the people in the photographs and videos. In light of the new
charges and the addition of Accuser-4, these must be re-reviewed, which will take weeks.
superseding indictment by using term searches and key word searches. But given the nature of
the discovery, there are meaningful limits to what the defense can do to limit the number of
documents it must re-review in light of the new charges. For example, the discovery contains
approximately 214,000 photographs, hundreds of hours of audio-visual files, and over 250,000
documents where the text is too poor to be OCR-searchable. Those materials are not susceptible
to text searching and must be reviewed individually. Moreover, they must be reviewed with Ms.
Maxwell to see if she recognizes the people in the photographs and videos. In light of the new
charges and the addition of Accuser-4, these must be re-reviewed, which will take weeks.
We have already experienced the difficulties of reviewing photographs with Ms.
Maxwell. Over the past three days, defense counsel have been conducting an evidence view
with Ms. Maxwell. As part of that review, we have tried to use an FBI-supplied laptop and hard
drive to review approximately 2,100 “Highly Confidential” photographs that were not produced
to us in discovery. Because of technical issues with the laptop, we still have not completed the
review.
Maxwell. Over the past three days, defense counsel have been conducting an evidence view
with Ms. Maxwell. As part of that review, we have tried to use an FBI-supplied laptop and hard
drive to review approximately 2,100 “Highly Confidential” photographs that were not produced
to us in discovery. Because of technical issues with the laptop, we still have not completed the
review.
The re-review of the discovery will not be limited to the materials on the seized devices.
The discovery also includes numerous bank records and phone records that date from the 2000s
and later. None of these records were from the 1990s and were therefore largely irrelevant to the
charged crimes. However, with the expansion of the charges to include the time period of the
2000s, the defense will need to carefully analyze these records for relevant payments and phone
calls, which will, again, take a significant amount of time.
The discovery also includes numerous bank records and phone records that date from the 2000s
and later. None of these records were from the 1990s and were therefore largely irrelevant to the
charged crimes. However, with the expansion of the charges to include the time period of the
2000s, the defense will need to carefully analyze these records for relevant payments and phone
calls, which will, again, take a significant amount of time.
The government also attempts to justify its delay in seeking the superseding indictment
due to the investigative challenges posed by COVID. The government has been investigating for
due to the investigative challenges posed by COVID. The government has been investigating for
The forensic images contain thousands of individual documents.
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DOJ-OGR-00001392
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