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660 KB

Extraction Summary

3
People
4
Organizations
0
Locations
3
Events
2
Relationships
4
Quotes

Document Information

Type: Legal filing (defense letter/motion)
File Size: 660 KB
Summary

This is page 7 of a legal filing by the Law Offices of Bobbi C. Sternheim dated April 15, 2021, in the case against Ghislaine Maxwell. The defense argues for a continuance (delay) of the trial due to a second superseding indictment which doubles Maxwell's sentencing exposure, while noting that continued detention prejudices the defendant. It also mentions an upcoming bail appeal hearing at the Second Circuit scheduled for April 26th.

People (3)

Name Role Context
Ghislaine Maxwell Defendant
Referred to as 'Ms. Maxwell'; subject of the indictment, detention, and bail appeal.
Bobbi C. Sternheim Defense Attorney
Name appears in the letterhead 'LAW OFFICES OF BOBBI C. STERNHEIM'.
The Court Judiciary
The judge/court overseeing the case.

Organizations (4)

Name Type Context
Law Offices of Bobbi C. Sternheim
Second Circuit
Scheduled to hear oral arguments on bail appeal.
The Government
Referring to the US Attorney's office/DOJ prosecuting the case.
DOJ
Referenced in the Bates stamp 'DOJ-OGR'.

Timeline (3 events)

2021-04-15
Document Filed
Court
2021-04-26
Oral argument on bail appeal
Second Circuit Court
Second Circuit Ms. Maxwell's Counsel
2021-07-12
Scheduled/Proposed Trial Date
Court
Ms. Maxwell

Relationships (2)

Bobbi C. Sternheim Attorney-Client Ghislaine Maxwell
Letterhead indicates Sternheim's office is filing arguments on behalf of Maxwell.
Ghislaine Maxwell Adversarial/Legal The Government
Document discusses government's trial estimates and indictments against Maxwell.

Key Quotes (4)

"The new charges up the ante and double Ms. Maxwell’s sentencing exposure."
Source
DOJ-OGR-00002931.jpg
Quote #1
"To deny her a continuance undercuts her constitutional right to a fair trial and effective assistance of counsel."
Source
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Quote #2
"The denial of a continuance risks a miscarriage of justice."
Source
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Quote #3
"she is the victim on ongoing hostile media reporting which impacts the ability to seat fair and impartial jurors."
Source
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Quote #4

Full Extracted Text

Complete text extracted from the document (1,891 characters)

Case 1:20-cr-00330-AJN Document 202 Filed 04/15/21 Page 7 of 8
LAW OFFICES OF BOBBI C. STERNHEIM
government in person to confer on a briefing schedule for supplemental pretrial motions, as well
as other deadlines, which we are prepared to discuss with the Court at the arraignment.
The government’s revised trial estimate from two to four weeks remains unrealistic and
does not include jury selection, which will take longer than usual in this media-saturated case.
We oppose advancing jury selection beyond early distribution of questionnaires to prospective
jurors. Even if the case were tried on the previous indictment on July 12th, carving off any time
required for trial preparation is unwarranted and unfair.
A continuance is justified based on the second superseding indictment. The new charges
up the ante and double Ms. Maxwell’s sentencing exposure. To deny her a continuance
undercuts her constitutional right to a fair trial and effective assistance of counsel. A
continuance - the need for which is caused solely by the government - is reasonable and
necessary in defense of Ms. Maxwell. The denial of a continuance risks a miscarriage of justice.
Despite Its Necessity, A Continuance Further Prejudices Ms. Maxwell
A delay of the July 12th trial – especially one that accommodates counsel’s other trial
schedules – has a direct and deleterious impact on Ms. Maxwell as a result of her continued
detention, the details of which are well known to the Court. In addition to her prolonged
detention, she is the victim on ongoing hostile media reporting which impacts the ability to seat
fair and impartial jurors.
On April 26th, Second Circuit will hear oral argument on Ms. Maxwell’s bail appeal and
may moot any need for a further bail application. Nonetheless, Ms. Maxwell reserves her right to
seek a bail hearing depending on the Circuit’s decision.
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DOJ-OGR-00002931

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