DOJ-OGR-00008385.jpg

685 KB

Extraction Summary

7
People
3
Organizations
4
Locations
2
Events
2
Relationships
4
Quotes

Document Information

Type: Legal correspondence / defense letter
File Size: 685 KB
Summary

A legal letter from defense attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the trial of Ghislaine Maxwell. The letter argues that the government used suggestive questioning techniques on accusers, specifically citing an instance where a witness named 'Jane' changed her testimony regarding a trip to New York and seeing 'The Lion King' after pressure from AUSA Rossmiller. The defense uses this to justify the necessity of expert testimony from Dr. Loftus regarding memory and suggestive questioning.

People (7)

Name Role Context
Bobbi C. Sternheim Defense Attorney
Author of the letter representing Ghislaine Maxwell.
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.
Dr. Loftus Expert Witness
Defense expert whose testimony the government is attempting to limit regarding memory and suggestive questioning.
Agent Young FBI Agent/Witness
Expected to testify about the form of questions asked during interviews.
Jane Accuser/Witness
Pseudonym for a witness whose memory/testimony regarding trips to New York and abuse in New Mexico is being challenge...
AUSA Rossmiller Assistant US Attorney (Prosecutor)
Accused of suggesting to Jane's lawyer that the government would 'assume' facts about Jane's trips to New York contra...

Organizations (3)

Name Type Context
Law Offices of Bobbi C. Sternheim
Defense counsel firm.
United States District Court
Venue of the trial.
DOJ
Department of Justice (referenced in footer bates stamp).

Timeline (2 events)

2021-12-15
Filing of Document 547 in Case 1:20-cr-00330-AJN.
New York, NY
Unknown (Jane was age 14)
Jane's trip to New York to see The Lion King on Broadway.
New York, NY

Locations (4)

Location Context
Address of Bobbi C. Sternheim.
Address of the United States Courthouse.
Location mentioned regarding questioning about sexual abuse.
Location of Jane's trips and the Broadway show.

Relationships (2)

Bobbi C. Sternheim Attorney-Client Ghislaine Maxwell
Header indicates Law Offices of Bobbi C. Sternheim; Subject line is United States v. Ghislaine Maxwell.
AUSA Rossmiller Prosecutor-Witness Jane
Document describes Rossmiller communicating with Jane's lawyer regarding her testimony.

Key Quotes (4)

"The government’s limitation on Dr. Loftus’s testimony is a desperate attempt to restrict relevant testimony."
Source
DOJ-OGR-00008385.jpg
Quote #1
"Accusers were asked suggestive questions during interviews and prep sessions with the government."
Source
DOJ-OGR-00008385.jpg
Quote #2
"AUSA Rossmiller told her lawyer that the government would just 'assume' that The Lion King trip was not her first trip to New York, even though that is what Jane had reported to them."
Source
DOJ-OGR-00008385.jpg
Quote #3
"True to form, at her very next call with the government a few weeks later, she followed their lead and 'remembered' that the Lion King trip had not been her first trip to New York."
Source
DOJ-OGR-00008385.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (1,865 characters)

Case 1:20-cr-00330-AJN Document 547 Filed 12/15/21 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
December 15, 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:
The government’s limitation on Dr. Loftus’s testimony is a desperate attempt to restrict relevant
testimony. Accusers were asked suggestive questions during interviews and prep sessions with the
government. We anticipate that Agent Young will be testifying about the form of questions asked
during such interviews and prep sessions. A review of the 3500 material and Jane's testimony exemplify
the type of questioning the government posited during their investigation.
By way of example, during cross examination, Jane was asked about the government’s repeated
questioning regarding whether sexual abuse occurred in New Mexico, during two separate interviews
and, during one of those interviews, three separate times. TR 512-516. Also, the government challenged
Jane’s recollection that she had seen The Lion King on Broadway during her first trip to New York at
age 14, outright suggesting that she saw the movie instead. When Jane’s counsel confirmed that she had
seen the Broadway show, not the movie, AUSA Rossmiller told her lawyer that the government would
just “assume” that The Lion King trip was not her first trip to New York, even though that is what Jane
had reported to them. TR. 503-511; see 3509-010. True to form, at her very next call with the
government a few weeks later, she followed their lead and “remembered” that the Lion King trip had not
been her first trip to New York. See 3509-011.
DOJ-OGR-00008385

Discussion 0

Sign in to join the discussion

No comments yet

Be the first to share your thoughts on this epstein document