DOJ-OGR-00005385.jpg

710 KB

Extraction Summary

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

Document Information

Type: Legal correspondence / court filing
File Size: 710 KB
Summary

A legal letter from attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The defense argues against the government's request to finalize jury selection on November 19, preferring November 29 to account for potential COVID-19 exposure and biases arising during the Thanksgiving holiday break. The document highlights procedural disagreements between the defense and the government regarding trial scheduling.

People (3)

Name Role Context
Bobbi C. Sternheim Defense Attorney
Author of the letter representing the defense.
Alison J. Nathan United States District Judge
Recipient of the letter, presiding judge.
Ghislaine Maxwell Defendant
Subject of the case (United States v. Ghislaine Maxwell).

Organizations (3)

Name Type Context
Law Offices of Bobbi C. Sternheim
Defense counsel's firm.
United States District Court
The court handling the case.
Department of Justice (DOJ)
Implied by 'DOJ-OGR' footer and references to 'the government'.

Timeline (3 events)

2021-10-21
Court Conference
Court
Defense Counsel Government Counsel Judge Nathan
2021-11-19
Proposed date for exercising challenges to final venire (Government preference)
Court
Counsel Jury
2021-11-29
Proposed date for exercising challenges/Firm start date (Defense preference)
Court
Counsel Jury

Locations (2)

Location Context
Law Offices of Bobbi C. Sternheim address.
United States Courthouse address.

Relationships (2)

Bobbi C. Sternheim Attorney-Client Ghislaine Maxwell
Letterhead and subject line 'United States v. Ghislaine Maxwell' indicate Sternheim is defense counsel.
Bobbi C. Sternheim Legal Professional Alison J. Nathan
Formal correspondence from attorney to judge.

Key Quotes (3)

"The Court merely invited a discrete response to its proposed address to prospective jury but the government seized the opportunity to reargue."
Source
DOJ-OGR-00005385.jpg
Quote #1
"If last year was any indication, Thanksgiving week is a likely time for COVID to spike due to high-volume travel, students returning home from college, and friends and families congregating."
Source
DOJ-OGR-00005385.jpg
Quote #2
"Even an exposure to the virus during the holidays can necessitate a prospective juror to quarantine for a time period past November 29."
Source
DOJ-OGR-00005385.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (1,997 characters)

Case 1:20-cr-00330-PAE Document 375 Filed 10/27/21 Page 1 of 2
LAW OFFICES OF BOBBI C. STERNHEIM
212-243-1100 • Main
917-912-9698 • Cell
888-587-4737 • Fax
225 Broadway, Suite 715
New York, NY 10007
bcsternheim@mac.com
October 27, 2021
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell
S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
In response to the Court’s Order dated October 22, 2021, regarding the Court’s draft preliminary remarks for prospective jurors (Dkt. 366), the government took the opportunity to reargue its request that counsel exercise challenges to the final venire on the last day of jury section (November 19) rather than on November 29. The Court merely invited a discrete response to its proposed address to prospective jury but the government seized the opportunity to reargue.
During the October 21 conference, the defense stated its reasons for preferring November 29, a date when the Court could inquire whether any prospective jury might not be able to be fair or otherwise impacted or influenced by any reference to this case during the 10-day interval that included the Thanksgiving holiday. Further, it would eliminate the need to substitute alternates in the event any juror was exposed to COVID or otherwise became ill. If last year was any indication, Thanksgiving week is a likely time for COVID to spike due to high-volume travel, students returning home from college, and friends and families congregating. Even an exposure to the virus during the holidays can necessitate a prospective juror to quarantine for a time period past November 29.
During the conference, the government pressed for November 19 because it wanted a have a firm start date for witnesses coming from out of state. November 29 is the firm start date and openings will commence following exercise of challenges and the swearing in of the jury. The government appears
DOJ-OGR-00005385

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