DOJ-OGR-00001394.jpg
518 KB
Extraction Summary
2
People
3
Organizations
0
Locations
4
Events
2
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
518 KB
Summary
This legal document, filed by the Law Offices of Bobbi C. Sternheim on behalf of Ms. Maxwell, requests a 90-day continuance for her trial, originally set for July 12, 2021. The defense argues that the government's recent disclosure of 226 witnesses necessitates more time for investigation and preparation. The request is made reluctantly, acknowledging it will prolong Ms. Maxwell's 'miserable and punishing detention'.
People (2)
| Name | Role | Context |
|---|---|---|
| BOBBI C. STERNHEIM | Attorney |
Mentioned in the header as the name of the law office filing the document.
|
| Ms. Maxwell | Defendant |
The client on whose behalf the legal motion is being filed. The document requests a continuance for her trial and dis...
|
Organizations (3)
| 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.
|
| Court | Judicial body |
Addressed throughout the document as the body that can order the government to disclose information and grant a conti...
|
| government | Government agency |
Referred to as the opposing party (prosecution) in the legal case, whose actions (disclosing 226 witnesses) necessita...
|
Timeline (4 events)
2021-04-12
The government's disclosure of information and statements regarding 226 witnesses.
government
defense counsel
2021-04-18
A meeting mentioned as having occurred 'Yesterday'. The document is dated April 19, 2021.
we
2021-07-12
The originally scheduled trial date for Ms. Maxwell's case.
Relationships (2)
The document is from the 'LAW OFFICES OF BOBBI C. STERNHEIM' and is filed on behalf of 'Ms. Maxwell', indicating an attorney-client relationship.
The document outlines a legal conflict where the 'government' is prosecuting 'Ms. Maxwell', who is the defendant.
Full Extracted Text
Complete text extracted from the document (2,223 characters)
Case 1:20-cr-00330-AJN Document 202 Filed 04/19/21 Page 6 of 8
LAW OFFICES OF BOBBI C. STERNHEIM
witnesses, including potential FRE 404(b) witnesses, and trial exhibits, the government’s
speculation about the length of the trial is entirely one-sided and lacking in any reliable estimate
of a defense case. The government’s April 12th disclosure of information and statements
regarding 226 witnesses containing exculpatory information requires intensive investigation.
The delayed expansion of its prosecution and its unilateral expansion of the length of trial
severely impacts defense preparation, trial readiness, and conflicts with other trial commitments.
speculation about the length of the trial is entirely one-sided and lacking in any reliable estimate
of a defense case. The government’s April 12th disclosure of information and statements
regarding 226 witnesses containing exculpatory information requires intensive investigation.
The delayed expansion of its prosecution and its unilateral expansion of the length of trial
severely impacts defense preparation, trial readiness, and conflicts with other trial commitments.
To assist the Court and defense counsel in accurately determining the length of trial, Ms.
Maxwell requests that the Court order the government to disclose: a list of trial witnesses, its
alleged FRE 404(b) evidence, and a list of potential trial exhibits. With this information the
Court and the parties will be making decisions based on facts, not speculative promises.
Maxwell requests that the Court order the government to disclose: a list of trial witnesses, its
alleged FRE 404(b) evidence, and a list of potential trial exhibits. With this information the
Court and the parties will be making decisions based on facts, not speculative promises.
At the barest minimum, we require a 90-day continuance. In reliance on the firm trial
date set by the Court at Ms. Maxwell’s arraignment on July 14th, 2020, counsel prioritized the
July 12, 2021 trial date, clearing and scheduling our calendars to avoid interference. Counsel
have other clients and firm commitments to try cases specifically scheduled to follow the
summer trial of this case. These commitments make us unavailable from September through
December, and possibly spill over into January, make trying this case unlikely, if not impossible,
before mid-January. We are extremely hard pressed to request any continuance, especially one
which will prolong Ms. Maxwell’s miserable and punishing detention, but the need for time to
properly prepare Ms. Maxwell’s defense as a result of the additional charges requires us to do so,
causing Ms. Maxwell to reluctantly agree to this request.
date set by the Court at Ms. Maxwell’s arraignment on July 14th, 2020, counsel prioritized the
July 12, 2021 trial date, clearing and scheduling our calendars to avoid interference. Counsel
have other clients and firm commitments to try cases specifically scheduled to follow the
summer trial of this case. These commitments make us unavailable from September through
December, and possibly spill over into January, make trying this case unlikely, if not impossible,
before mid-January. We are extremely hard pressed to request any continuance, especially one
which will prolong Ms. Maxwell’s miserable and punishing detention, but the need for time to
properly prepare Ms. Maxwell’s defense as a result of the additional charges requires us to do so,
causing Ms. Maxwell to reluctantly agree to this request.
In addition, motion hearings, in limine motion practice, and any litigation regarding
expert witnesses have not yet commenced, and issues regarding jury selection, including but not
limited to a jury questionnaire, have not yet been settled. Yesterday, we met with the
expert witnesses have not yet commenced, and issues regarding jury selection, including but not
limited to a jury questionnaire, have not yet been settled. Yesterday, we met with the
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DOJ-OGR-00001394
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