DOJ-OGR-00005744.jpg
494 KB
Extraction Summary
6
People
4
Organizations
3
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Court filing (legal motion/memorandum)
File Size:
494 KB
Summary
This is a page from a legal motion filed on October 29, 2021, by Ghislaine Maxwell's defense team (Case 1:20-cr-00330-PAE). The attorneys argue that a redacted individual's identification of Maxwell should be suppressed because the individual never previously identified Maxwell as an abuser in interviews or under oath. The document asserts that the identification procedure was suggestive and occurred too long after the alleged events.
People (6)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the defense motion; accused of crimes but defense argues she did not participate.
|
| [REDACTED] | Witness/Accuser |
Name redacted throughout the text; described as having never identified Maxwell as an abuser in previous interviews o...
|
| Jeffrey S. Pagliuca | Attorney |
Defense counsel for Ghislaine Maxwell; Haddon, Morgan & Foreman P.C.
|
| Laura A. Menninger | Attorney |
Defense counsel for Ghislaine Maxwell; Haddon, Morgan & Foreman P.C.
|
| Christian R. Everdell | Attorney |
Defense counsel for Ghislaine Maxwell; Cohen & Gresser LLP.
|
| Bobbi C. Sternheim | Attorney |
Defense counsel for Ghislaine Maxwell; Law Offices of Bobbi C. Sternheim.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| HADDON, MORGAN & FOREMAN P.C. |
Law firm representing Maxwell (Denver).
|
|
| COHEN & GRESSER LLP |
Law firm representing Maxwell (New York).
|
|
| Law Offices of Bobbi C. Sternheim |
Law firm representing Maxwell (New York).
|
|
| DOJ |
Department of Justice (indicated in footer stamp DOJ-OGR).
|
Timeline (2 events)
October 18, 2021
Submission of the legal motion.
Court (implied)
Locations (3)
| Location | Context |
|---|---|
|
Address for Haddon, Morgan & Foreman P.C.
|
|
|
Address for Cohen & Gresser LLP.
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|
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Address for Law Offices of Bobbi C. Sternheim.
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Relationships (2)
Text discusses the redacted person's identification (or lack thereof) of Maxwell regarding alleged abuse.
Signed as 'Attorneys for Ghislaine Maxwell'
Key Quotes (4)
"the linchpin of admissibility is reliability."Source
DOJ-OGR-00005744.jpg
Quote #1
"[REDACTED] in interviews, court filings, and under oath, never identified Ms. Maxwell as anyone who abused her in any fashion."Source
DOJ-OGR-00005744.jpg
Quote #2
"There was no “opportunity” for [REDACTED] to “view the criminal at the time of the crime” because Ms. Maxwell did not participate in any crime."Source
DOJ-OGR-00005744.jpg
Quote #3
"Accordingly, any identification, both out of court and in court, should be suppressed."Source
DOJ-OGR-00005744.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,264 characters)
Case 1:20-cr-00330-PAE Document 392 Filed 10/29/21 Page 7 of 8
at 114. The factors must be assessed in light of the totality of the circumstances, and the linchpin
of admissibility is reliability.
of admissibility is reliability.
Here, the factors weigh heavily in favor of suppression. [REDACTED] in interviews,
court filings, and under oath, never identified Ms. Maxwell as anyone who abused her in any
fashion. There was no “opportunity” for [REDACTED] to “view the criminal at the time of the
crime” because Ms. Maxwell did not participate in any crime. There was no prior description of
Ms. Maxwell by [REDACTED] and the length of time between the alleged event and the
suggestive identification procedure was extraordinarily long.
court filings, and under oath, never identified Ms. Maxwell as anyone who abused her in any
fashion. There was no “opportunity” for [REDACTED] to “view the criminal at the time of the
crime” because Ms. Maxwell did not participate in any crime. There was no prior description of
Ms. Maxwell by [REDACTED] and the length of time between the alleged event and the
suggestive identification procedure was extraordinarily long.
Accordingly, any identification, both out of court and in court, should be suppressed.
Dated: October 18, 2021
Respectfully submitted,
s/ Jeffrey S. Pagliuca
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303-831-7364
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303-831-7364
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Phone: 212-957-7600
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Phone: 212-957-7600
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
Phone: 212-243-1100
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
Phone: 212-243-1100
Attorneys for Ghislaine Maxwell
4
DOJ-OGR-00005744
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