DOJ-OGR-00020312.jpg
518 KB
Extraction Summary
2
People
3
Organizations
0
Locations
2
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal filing / defense letter motion
File Size:
518 KB
Summary
This document is page 6 of a legal filing by the Law Offices of Bobbi C. Sternheim on behalf of Ghislaine Maxwell, dated April 19, 2021. The defense is requesting a 90-day continuance (delay) of the trial scheduled for July 12, 2021, citing a recent government disclosure regarding 226 witnesses and scheduling conflicts. The document highlights the defense's need for time to investigate exculpatory information and complains about the government's unilateral expansion of the prosecution.
People (2)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the defense motion requesting a continuance; described as being in 'miserable and punishing detention'.
|
| Bobbi C. Sternheim | Defense Attorney |
Author of the document (Law Offices of Bobbi C. Sternheim header).
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim | ||
| The Government |
Referenced regarding disclosures and trial length speculation.
|
|
| The Court |
Recipient of the request for continuance.
|
Timeline (2 events)
Relationships (1)
Document header and context of defense arguments.
Key Quotes (4)
"At the barest minimum, we require a 90-day continuance."Source
DOJ-OGR-00020312.jpg
Quote #1
"The government’s April 12th disclosure of information and statements regarding 226 witnesses containing exculpatory information requires intensive investigation."Source
DOJ-OGR-00020312.jpg
Quote #2
"We are extremely hard pressed to request any continuance, especially one which will prolong Ms. Maxwell’s miserable and punishing detention..."Source
DOJ-OGR-00020312.jpg
Quote #3
"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."Source
DOJ-OGR-00020312.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,224 characters)
Case 1:20-cr-00330-AJN Document 264 Filed 04/19/2021 Page 6 of 8
LAW OFFICES OF BOBBI C. STERNHEIM
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.
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.
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.
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
6
DOJ-OGR-00020312
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document