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511 KB

Extraction Summary

2
People
3
Organizations
2
Locations
2
Events
2
Relationships
1
Quotes

Document Information

Type: Legal document
File Size: 511 KB
Summary

This legal document is a motion filed by the defense counsel for Ms. Maxwell, arguing for a continuance (postponement) of her trial scheduled for July 12, 2021. The defense claims that the challenges of preparing for the case during the COVID-19 pandemic, combined with the need to review voluminous discovery and investigate new allegations, make it impossible to be ready by the scheduled date. The filing refutes the government's assertion of trial readiness and details the extensive work still required for an adequate defense.

People (2)

Name Role Context
Ms. Maxwell Defendant
The individual being prosecuted, on whose behalf this legal motion for a trial continuance is being made.
BOBBI C. STERNHEIM Counsel
Her law office is representing Ms. Maxwell, as indicated by the letterhead.

Organizations (3)

Name Type Context
LAW OFFICES OF BOBBI C. STERNHEIM Law firm
Appears in the letterhead of the document, representing the defense.
U.S. Government Government agency
Referred to as "the government," it is the prosecuting party in the case against Ms. Maxwell.
The Court Judiciary
The judicial body to which this motion is being presented.

Timeline (2 events)

2020-11
The government produced voluminous discovery materials that the defense needs to review.
U.S. Government Defense counsel
2021-07-12
The scheduled start date for the trial of Ms. Maxwell, which the defense is arguing to postpone.

Locations (2)

Location Context
Mentioned as "this country" where investigations for the defense are required.
Mentioned as "around the world," indicating the international scope of the required defense investigation.

Relationships (2)

BOBBI C. STERNHEIM Attorney-Client Ms. Maxwell
The document is from the "LAW OFFICES OF BOBBI C. STERNHEIM" and is written on behalf of the defendant, "Ms. Maxwell."
Ms. Maxwell Adversarial (Defendant-Prosecutor) U.S. Government
The document details the government's prosecution of Ms. Maxwell and the defense's arguments against the government's proposed trial schedule.

Key Quotes (1)

"ensure that the defense will be fully prepared to proceed to trial on July 12, 2021"
Source
— Govt (Government) (A quote from a government letter, described by the defense as a "hyperbolic claim" that ignores the reality of the preparation needed.)
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Quote #1

Full Extracted Text

Complete text extracted from the document (2,167 characters)

Case 20-tr-580320-AWN Document 76 Filed 04/19/2021 Page 30 of 8
LAW OFFICES OF BOBBI C. STERNHEIM
years and elected to commence prosecution of Ms. Maxwell in the throes of the pandemic. All counsel have been laboring under the difficulties caused by this unprecedented circumstance. The government’s challenges pale in comparison to those experienced by the defense.
Defending quarter-century-old allegations has required investigation across this country and around the world. Investigating the new allegations will require the same efforts and diligence. It is laughable for the government to use COVID as an excuse for its delay in superseding the indictment and then oppose any continuance for the defense. Defense preparation is not immune to the impact of the pandemic.
A Trial Continuance is Necessary
While the government’s offer to provide discovery highlights and its representation that it will streamline its case to primarily focus on the four accusers are helpful, these gestures do not eliminate the need for a continuance. As set forth above, the government’s hyperbolic claim that it can “ensure that the defense will be fully prepared to proceed to trial on July 12, 2021” (Govt ltr at 4-5) ignores the reality that time is needed to:
- supplement pending pretrial motions;
- critically review voluminous discovery produced in November 2020 that the government represented was not relevant to the case against Ms. Maxwell;
- re-review discovery for the new time period and charges;
- commence new investigations based on the new charges and the government’s disclosure of 3500 material for non-testifying witnesses; and
- refocus trial preparation and strategy.
The government originally represented to the Court and counsel that this trial would last two weeks. The government now predicts the trial will last a month. The estimates are mere guesses which do not factor in time-consuming COVID jury selection in a high-publicity case necessitating sensitive and personal disclosures by prospective jurors or the presentation of defense evidence. In the absence of disclosure of the number and identity of government trial
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DOJ-OGR-00020311

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