DOJ-OGR-00002339.jpg
918 KB
Extraction Summary
3
People
4
Organizations
3
Locations
2
Events
3
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
918 KB
Summary
This document is a letter dated February 1, 2021, from attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. Sternheim argues against the Metropolitan Detention Center's (MDC) objection to allowing Maxwell laptop access on weekends and holidays to review millions of pages of discovery documents. The letter asserts that the MDC's proposed alternative, a prison computer, is inadequate for the task and that the MDC has failed to provide a valid security or staffing reason for restricting laptop access, thereby impeding Maxwell's ability to prepare her defense.
People (3)
| Name | Role | Context |
|---|---|---|
| Bobbi C. Sternheim | Attorney |
The letter is from the Law Offices of Bobbi C. Sternheim, presumably representing Ghislaine Maxwell.
|
| Alison J. Nathan | Honorable United States District Judge |
The letter is addressed to her regarding a case in her court.
|
| Ghislaine Maxwell | Defendant |
The subject of the letter, which concerns her ability to review discovery materials for her case, United States v. Gh...
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| LAW OFFICES OF BOBBI C. STERNHEIM | Law firm |
The letterhead indicates this is the sender of the document.
|
| United States District Court | Government agency |
The court where Judge Alison J. Nathan presides and where the case is being heard.
|
| MDC | Government agency |
The Metropolitan Detention Center where Ms. Maxwell is being held. The letter discusses the MDC's objection to her us...
|
| United States | Government |
The prosecuting party in the case 'United States v. Ghislaine Maxwell'.
|
Timeline (2 events)
2021-02-01
The Law Offices of Bobbi C. Sternheim filed a letter with the court regarding Ghislaine Maxwell's access to a laptop for discovery review.
United States District Court
Locations (3)
| Location | Context |
|---|---|
|
The address of the Law Offices of Bobbi C. Sternheim.
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|
|
The address of the United States District Court where Judge Nathan presides.
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|
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The city where both the law office and the courthouse are located.
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Relationships (3)
The letter is from the Law Offices of Bobbi C. Sternheim and argues on behalf of Ms. Maxwell in her criminal case.
Judge Nathan is presiding over the criminal case against Ms. Maxwell.
Sternheim, as counsel, is addressing Judge Nathan, who is presiding over the case.
Key Quotes (1)
"manag[e] its inmate population."Source
— the government
(Cited as a potential but unused reason by the MDC for denying laptop access, attributed to the government.)
DOJ-OGR-00002339.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (2,810 characters)
Case 1:20-cr-00330-AJN Document 130 Filed 02/01/21 Page 1 of 3
LAW OFFICES OF BOBBI C. STERNHEIM
LAW OFFICES OF BOBBI C. STERNHEIM
212-243-1100 • Main
917-306-6666 • Cell
888-587-4737 • Fax
917-306-6666 • Cell
888-587-4737 • Fax
33 West 19th Street - 4th Floor
New York, New York 10011
bc@sternheimlaw.com
New York, New York 10011
bc@sternheimlaw.com
February 1, 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
20 Cr. 330 (AJN)
20 Cr. 330 (AJN)
Dear Judge Nathan:
By letter to the Court, dated January 25, 2021 (Dkt. 117 at 2-3), the MDC raised objection to the Court’s order, unopposed by the government, directing the MDC to permit Ms. Maxwell to use on a laptop computer on weekends and holidays. (Dkt. 116 at 2). The MDC has failed to state a valid or compelling reason for opposing the Court’s directive.
The MDC does not identify any valid reason why Ms. Maxwell cannot have access to the laptop computer on weekends and holidays. The MDC does not argue, for example, that access to the laptop cannot be provided because of issues related to safety or security, staffing, or (to quote the government) the need to “manag[e] its inmate population.” Instead, in opposition to the Court’s order, the MDC repeats its stock response: Ms. Maxwell has received significant amount of time to review her discovery and has more contact with counsel than any other MDC inmate is allotted. The MDC’s fixation on the relative time Ms. Maxwell has been given to review discovery is totally misguided. The government has produced millions of pages of discovery. Ms. Maxwell has the right to review all of them in order to prepare her defense for trial. To do that, she needs access to the laptop for as much time as possible, including the weekends and holidays because the prison computers are incapable of reading the millions of discovery documents. Ms. Maxwell loses 10 or more hours per week due to delay in receiving the laptop, problems caused by the MDC computer, and inability to access the computer during morning and afternoon counts on the weekends. Comparing Ms. Maxwell to other inmates does not justify restricting her use of the laptop to review discovery.
The MDC’s proposed solution—that Ms. Maxwell can simply use the prison computer on the weekends and holidays to review discovery—is utterly inadequate. As Ms. Maxwell has pointed out on many occasions, the prison computer is incapable of reading a significant portion of the discovery, including but not limited to native files, Excel files, some video and audio files, and anything requiring Cellebrite software. The MDC concedes this fact in their letter—Ms. Maxwell cannot review all of her discovery on the prison computer. And using it causes a colossal waste of time. For example, if Ms. Maxwell locates a document on the prison computer
DOJ-OGR-00002339
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