DOJ-OGR-00005365.jpg

620 KB

Extraction Summary

12
People
3
Organizations
1
Locations
2
Events
3
Relationships
4
Quotes

Document Information

Type: Legal filing (jury questionnaire / voir dire draft with comments)
File Size: 620 KB
Summary

This document is a page from a legal filing (Case 1:20-cr-00330-PAE) dated October 22, 2021, containing proposed voir dire questions (21-25) for the jury selection in the trial of Ghislaine Maxwell. It lists the specific legal teams for both the defense (led by Everdell, Menninger, Pagliuca, Sternheim) and the prosecution (led by US Attorney Damian Williams and AUSAs Comey, Moe, Pomerantz, Rohrbach). The document includes margin comments highlighting a dispute between the prosecution and defense regarding whether to refer to Maxwell as 'the defendant' or 'the accused'.

People (12)

Name Role Context
Ghislaine Maxwell Defendant/Accused
Subject of the trial, represented by defense counsel mentioned.
Christian Everdell Defense Attorney
Representing Ghislaine Maxwell.
Laura Menninger Defense Attorney
Representing Ghislaine Maxwell.
Jeffrey Pagliuca Defense Attorney
Representing Ghislaine Maxwell.
Bobbi Sternheim Defense Attorney
Representing Ghislaine Maxwell.
Ann Lundberg Senior Paralegal Specialist
Assisting the defense team.
Damian Williams United States Attorney
Representing the Government/Prosecution (SDNY).
Maurene Comey Assistant United States Attorney
Prosecution team in immediate charge of the trial.
Alison Moe Assistant United States Attorney
Prosecution team in immediate charge of the trial.
Lara Pomerantz Assistant United States Attorney
Prosecution team in immediate charge of the trial.
Andrew Rohrbach Assistant United States Attorney
Prosecution team in immediate charge of the trial.
Amanda FBI Special Agent
Assisting the prosecution (Last name cut off in text).

Organizations (3)

Name Type Context
United States Attorney for the Southern District of New York
Prosecuting authority.
FBI
Investigative agency assisting the prosecution.
SEC
Mentioned in comment A11 as another agency representing the US Government.

Timeline (2 events)

2021-10-22
Filing of Document 367-1 in Case 1:20-cr-00330-PAE
Southern District of New York
Ghislaine Maxwell US Government
Future (relative to doc)
Jury Selection / Trial
Court
Jurors Ghislaine Maxwell Legal Teams

Locations (1)

Location Context
Jurisdiction of the court.

Relationships (3)

Ghislaine Maxwell Attorney-Client Christian Everdell
Maxwell is represented by Christian Everdell...
Ghislaine Maxwell Attorney-Client Bobbi Sternheim
Maxwell is represented by... Bobbi Sternheim.
Damian Williams Colleagues (Prosecution Team) Maurene Comey
Listed together as representing the Government.

Key Quotes (4)

"Ghislaine Maxwell is the defendant in the case, and should be referred to as such, as is the case in virtually every criminal prosecution."
Source
DOJ-OGR-00005365.jpg
Quote #1
"Ms. Maxwell is merely accused of the conduct included in the charges and this questionnaire, a point that bears repeating."
Source
DOJ-OGR-00005365.jpg
Quote #2
"Given the high-profile nature of this case and the sensitive nature of the charges, is there any reason why you would feel pressure... to return a verdict other than one based only on the evidence?"
Source
DOJ-OGR-00005365.jpg
Quote #3
"The conduct of the trial will be in the immediate charge of Assistant United States Attorneys Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach."
Source
DOJ-OGR-00005365.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (2,730 characters)

Case 1:20-cr-00330-PAE Document 367-1 Filed 10/22/21 Page 8 of 17
[Sidebar Comments]
Commented [A9]: GOVERNMENT OBJECTION: Ghislaine Maxwell is the defendant in the case, and should be referred to as such, as is the case in virtually every criminal prosecution.
Commented [A10R9]: DEFENDANT RESPONSE: Ms. Maxwell is merely accused of the conduct included in the charges and this questionnaire, a point that bears repeating.
Commented [A11]: DEFENDANT RESPONSE: The defense objects that this language is superfluous and unnecessary. No other "case before this Court" is at issue. Further, the U.S. Government is represented by numerous other parties before this Court, including the SEC and other agencies.
[Main Document Body]
21. If you are selected as a juror in this matter, after you have heard all the evidence, you will deliberate. During deliberations, if you find you are of one view and all the rest of the jurors of an opposite view, and if, after full and free discussion, you remain convinced by reason and by logic that you are correct, will you have the strength of your convictions to adhere to your decision, notwithstanding the fact that all the other jurors disagree with you?
22. If a friend or loved one was standing trial here, on the same charges, do you know of any reason why you would not be satisfied to have his or her case tried by someone in your frame of mind or with the attitudes and beliefs that you hold?
23. Given the high-profile nature of this case and the sensitive nature of the charges, is there any reason why you would feel pressure - personally, professionally, politically, ethically, or religiously - to return a verdict other than one based only on the evidence? [If Yes/Unsure, question privately.]
Knowledge of the Trial Participants
24. As noted in your questionnaire, the accused, the defendant, Ghislaine Maxwell, is represented by Christian Everdell, Laura Menninger, Jeffrey Pagliuca, and Bobbi Sternheim. [Please ask them to stand.] Seeing them here today, do any of you know Mr. Everdell, Ms. Menninger, Mr. Pagliuca, or Ms. Sternheim? Has any juror had any dealings with them or individuals in their offices? They will be assisted by senior paralegal specialist Ann Lundberg.
25. Similarly, as noted in your questionnaire, the prosecution, referred to here as the Government, is represented here, as in all cases where it is a party before this Court, by the United States Attorney for the Southern District of New York, Damian Williams. The conduct of the trial will be in the immediate charge of Assistant United States Attorneys Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach. They will be assisted by FBI Special Agent Amanda
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DOJ-OGR-00005365

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