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583 KB
Extraction Summary
8
People
4
Organizations
3
Locations
2
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal correspondence / court filing (defense letter motion)
File Size:
583 KB
Summary
This document is a legal letter filed on December 18, 2021, addressed to Judge Alison J. Nathan regarding the trial of Ghislaine Maxwell. The defense requests permission for a witness, Mr. Hamilton, to testify remotely from London via WebEx because he has tested positive for COVID-19 and cannot travel. The defense argues that precluding his testimony would violate Maxwell's constitutional rights to present a defense and confront accusers, specifically mentioning the need to expose the bias of an accuser named Kate.
People (8)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | Judge |
Recipient of the letter, presiding over Case 1:20-cr-00330-PAE.
|
| Mr. Hamilton | Defense Witness |
Resides in London, tested positive for COVID, unable to travel to trial. Defense requests remote testimony via WebEx.
|
| Ms. Maxwell | Defendant |
Ghislaine Maxwell. The document asserts her constitutional right to confront accusers and present a defense.
|
| Kate | Accuser/Witness |
Mentioned in the context of defense wanting to expose her 'motive and bias to the jury.'
|
| Judge Kaplan | Judge |
Cited in legal precedent (United States v. Khaled Al Fawwaz) for allowing remote testimony.
|
| Khaled Al Fawwaz | Defendant (Precedent Case) |
Defendant in cited case 98 Cr. 1023 (LAK).
|
| Nicholas Lewin | Former AUSA |
Cited in precedent case as having traveled to London for a deposition.
|
| Bobbi C. Sternheim | Defense Counsel |
Cited in precedent case as having traveled to London; implied author/counsel for Maxwell in current document.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| The Government |
Prosecution; moved for preclusion of Hamilton's testimony.
|
|
| SDNY |
Southern District of New York (Court jurisdiction/location).
|
|
| WebEx |
Video conferencing platform proposed for remote testimony.
|
|
| DOJ |
Department of Justice (referenced in footer DOJ-OGR).
|
Timeline (2 events)
Relationships (2)
Hamilton is a proposed defense witness for Maxwell.
Text mentions exposing Kate's motive and bias against Maxwell.
Key Quotes (5)
"We have notified the government that Mr. Hamilton, who resides in London, has tested positive for COVID."Source
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Quote #1
"The government has moved for preclusion of his testimony in toto."Source
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Quote #2
"We are requesting permission to have Mr. Hamilton testify from his home via a WebEx link to the Courtroom."Source
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Quote #3
"Ms. Maxwell has a constitutional right confront her accusers and to present a defense."Source
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Quote #4
"This Court should reject the government’s attempt to preclude Ms. Maxwell from exposing Kate’s motive and bias to the jury."Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (1,606 characters)
Case 1:20-cr-00330-PAE Document 555 Filed 12/18/21 Page 4 of 5
The Honorable Alison J. Nathan
December 15, 2021
Page 4
The Honorable Alison J. Nathan
December 15, 2021
Page 4
* * *
We have notified the government that Mr. Hamilton, who resides in London, has tested positive for COVID. We now have documentation of his test results. As a result, he cannot travel or attend the trial in person. In lieu of responding to our request to work out a stipulation based on Mr. Hamilton’s deposition, the government has moved for preclusion of his testimony in toto. We are requesting permission to have Mr. Hamilton testify from his home via a WebEx link to the Courtroom. In United States v. Khaled Al Fawwaz, 98 Cr. 1023 (LAK), Judge Kaplan ordered live CCTV testimony of a government witness who was unable to travel from London to SDNY due to a medical condition. Counsel for both parties (then-AUSA Nicholas Lewin and defense counsel Bobbi C. Sternheim, Esq.) traveled to London to conduct the examination which was transmitted via CCTV to Judge Kaplan’s courtroom for real-time viewing by the jury. Mr. Hamilton is quarantined and highly contagious. He should be permitted to testify remotely.
* * *
Ms. Maxwell has a constitutional right confront her accusers and to present a defense. U.S. Const. amends. V, VI. Precluding Mr. Hamilton from testifying, when his proposed testimony is proper under the Rules of Evidence, would violate these constitutional guarantees. This Court should reject the government’s attempt to preclude Ms. Maxwell from exposing Kate’s motive and bias to the jury.
This Court should deny the government’s motion.
DOJ-OGR-00008434
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