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511 KB

Extraction Summary

2
People
4
Organizations
0
Locations
2
Events
1
Relationships
3
Quotes

Document Information

Type: Legal filing (motion/letter)
File Size: 511 KB
Summary

A legal filing from the Law Offices of Bobbi C. Sternheim arguing for a continuance of Ghislaine Maxwell's trial. The defense cites the difficulties of preparing during the COVID-19 pandemic, the need to investigate new charges and 'quarter-century-old allegations,' and the review of voluminous discovery produced in November 2020. The document criticizes the government's timeline estimates and their opposition to the delay.

People (2)

Name Role Context
Ghislaine Maxwell Defendant
Subject of the prosecution; defense is arguing for a trial continuance on her behalf.
Bobbi C. Sternheim Defense Attorney
Author of the legal filing (indicated by letterhead).

Organizations (4)

Name Type Context
Law Offices of Bobbi C. Sternheim
Header of the document.
The Government
Opposing party in the case; criticized by the defense for opposing the continuance.
DOJ
Department of Justice (indicated by Bates stamp).
The Court
Recipient of the representations regarding trial length.

Timeline (2 events)

2020-11
Production of voluminous discovery
N/A
The Government Defense Counsel
2021-07-12
Proposed Trial Date
Court
Ms. Maxwell The Government Defense Counsel

Relationships (1)

Bobbi C. Sternheim Legal Representation Ghislaine Maxwell
Letterhead matches defense arguments for 'Ms. Maxwell'.

Key Quotes (3)

"It is laughable for the government to use COVID as an excuse for its delay in superseding the indictment and then oppose any continuance for the defense."
Source
DOJ-OGR-00001393.jpg
Quote #1
"Defending quarter-century-old allegations has required investigation across this country and around the world."
Source
DOJ-OGR-00001393.jpg
Quote #2
"The government originally represented to the Court and counsel that this trial would last two weeks. The government now predicts the trial will last a month."
Source
DOJ-OGR-00001393.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (2,165 characters)

Case 1:20-cr-00330-AJN Document 221 Filed 04/19/21 Page 5 of 8
LAW OFFICES OF BOBBI C. STERNHEIM
years and elected to commence prosecution of Ms. Maxwell in the throes of the pandemic. All
counsel have been laboring under the difficulties caused by this unprecedented circumstance.
The government’s challenges pale in comparison to those experienced by the defense.
Defending quarter-century-old allegations has required investigation across this country and
around the world. Investigating the new allegations will require the same efforts and diligence.
It is laughable for the government to use COVID as an excuse for its delay in superseding the
indictment and then oppose any continuance for the defense. Defense preparation is not immune
to the impact of the pandemic.
A Trial Continuance is Necessary
While the government’s offer to provide discovery highlights and its representation that it
will streamline its case to primarily focus on the four accusers are helpful, these gestures do not
eliminate the need for a continuance. As set forth above, the government’s hyperbolic claim that
it can “ensure that the defense will be fully prepared to proceed to trial on July 12, 2021” (Govt
ltr at 4-5) ignores the reality that time is needed to:
▪ supplement pending pretrial motions;
▪ critically review voluminous discovery produced in November 2020 that the
government represented was not relevant to the case against Ms. Maxwell;
▪ re-review discovery for the new time period and charges;
▪ commence new investigations based on the new charges and the government’s
disclosure of 3500 material for non-testifying witnesses; and
▪ refocus trial preparation and strategy.
The government originally represented to the Court and counsel that this trial would last
two weeks. The government now predicts the trial will last a month. The estimates are mere
guesses which do not factor in time-consuming COVID jury selection in a high-publicity case
necessitating sensitive and personal disclosures by prospective jurors or the presentation of
defense evidence. In the absence of disclosure of the number and identity of government trial
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DOJ-OGR-00001393

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