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752 KB
Extraction Summary
3
People
3
Organizations
0
Locations
2
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal filing (defense motion/memorandum)
File Size:
752 KB
Summary
This document is page 4 of a legal filing by the Law Offices of Bobbi C. Sternheim, dated April 15, 2021, regarding the defense of Ghislaine Maxwell. The text argues that the defense needs significant time to review discovery material due to the immense volume (214,000 photos, 250,000 non-searchable documents) and the filing of a superseding indictment adding 'Accuser-4' and expanding the timeframe to the 2000s. It also notes technical difficulties experienced with an FBI-supplied laptop while attempting to review 2,100 'Highly Confidential' photographs with Ms. Maxwell.
People (3)
| Name | Role | Context |
|---|---|---|
| Bobbi C. Sternheim | Defense Attorney |
Author of the legal filing, representing the Law Offices of Bobbi C. Sternheim.
|
| Ghislaine Maxwell | Defendant |
Referred to as 'Ms. Maxwell'; subject of the defense counsel's review and evidence view.
|
| Accuser-4 | Accuser/Victim |
Added in the new charges/superseding indictment, necessitating re-review of evidence.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim |
Legal firm representing the defendant.
|
|
| FBI |
Federal Bureau of Investigation; supplied a laptop and hard drive for evidence review.
|
|
| The Government |
Prosecution; mentioned regarding the delay in seeking the superseding indictment.
|
Timeline (2 events)
2021-04-12 to 2021-04-15
Defense counsel conducting an evidence view with Ms. Maxwell.
Not specified (Implied detention facility)
Defense Counsel
Ms. Maxwell
Relationships (1)
Sternheim's office filing on behalf of Maxwell; conducting evidence view with Ms. Maxwell.
Key Quotes (4)
"The discovery contains approximately 214,000 photographs, hundreds of hours of audio-visual files, and over 250,000 documents where the text is too poor to be OCR-searchable."Source
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Quote #1
"In light of the new charges and the addition of Accuser-4, these must be re-reviewed, which will take weeks."Source
DOJ-OGR-00002928.jpg
Quote #2
"As part of that review, we have tried to use an FBI-supplied laptop and hard drive to review approximately 2,100 “Highly Confidential” photographs that were not produced to us in discovery."Source
DOJ-OGR-00002928.jpg
Quote #3
"The discovery also includes numerous bank records and phone records that date from the 2000s and later."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,193 characters)
Case 1:20-cr-00330-AJN Document 202 Filed 04/15/21 Page 4 of 8
LAW OFFICES OF BOBBI C. STERNHEIM
LAW OFFICES OF BOBBI C. STERNHEIM
The defense has tried to streamline its review of the discovery even before the filing of
superseding indictment by using term searches and key word searches. But given the nature of
the discovery, there are meaningful limits to what the defense can do to limit the number of
documents it must re-review in light of the new charges. For example, the discovery contains
approximately 214,000 photographs, hundreds of hours of audio-visual files, and over 250,000
documents where the text is too poor to be OCR-searchable. Those materials are not susceptible
to text searching and must be reviewed individually. Moreover, they must be reviewed with Ms.
Maxwell to see if she recognizes the people in the photographs and videos. In light of the new
charges and the addition of Accuser-4, these must be re-reviewed, which will take weeks.
superseding indictment by using term searches and key word searches. But given the nature of
the discovery, there are meaningful limits to what the defense can do to limit the number of
documents it must re-review in light of the new charges. For example, the discovery contains
approximately 214,000 photographs, hundreds of hours of audio-visual files, and over 250,000
documents where the text is too poor to be OCR-searchable. Those materials are not susceptible
to text searching and must be reviewed individually. Moreover, they must be reviewed with Ms.
Maxwell to see if she recognizes the people in the photographs and videos. In light of the new
charges and the addition of Accuser-4, these must be re-reviewed, which will take weeks.
We have already experienced the difficulties of reviewing photographs with Ms.
Maxwell. Over the past three days, defense counsel have been conducting an evidence view
with Ms. Maxwell. As part of that review, we have tried to use an FBI-supplied laptop and hard
drive to review approximately 2,100 “Highly Confidential” photographs that were not produced
to us in discovery. Because of technical issues with the laptop, we still have not completed the
review.
Maxwell. Over the past three days, defense counsel have been conducting an evidence view
with Ms. Maxwell. As part of that review, we have tried to use an FBI-supplied laptop and hard
drive to review approximately 2,100 “Highly Confidential” photographs that were not produced
to us in discovery. Because of technical issues with the laptop, we still have not completed the
review.
The re-review of the discovery will not be limited to the materials on the seized devices.
The discovery also includes numerous bank records and phone records that date from the 2000s
and later. None of these records were from the 1990s and were therefore largely irrelevant to the
charged crimes. However, with the expansion of the charges to include the time period of the
2000s, the defense will need to carefully analyze these records for relevant payments and phone
calls, which will, again, take a significant amount of time.
The discovery also includes numerous bank records and phone records that date from the 2000s
and later. None of these records were from the 1990s and were therefore largely irrelevant to the
charged crimes. However, with the expansion of the charges to include the time period of the
2000s, the defense will need to carefully analyze these records for relevant payments and phone
calls, which will, again, take a significant amount of time.
The government also attempts to justify its delay in seeking the superseding indictment
due to the investigative challenges posed by COVID. The government has been investigating for
due to the investigative challenges posed by COVID. The government has been investigating for
The forensic images contain thousands of individual documents.
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