DOJ-OGR-00020608.jpg
547 KB
Extraction Summary
4
People
2
Organizations
1
Locations
2
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal motion / court filing (appellate court)
File Size:
547 KB
Summary
This document is page 3 of a legal motion filed on January 16, 2023, in Case 22-1426 (United States v. Maxwell appeal). The defense is requesting permission to file an oversized brief of 20,000 words, citing the complexity of the case, a 3,000-page trial transcript, and specific legal issues regarding evidentiary rulings, juror misconduct, and a non-prosecution agreement. The filing notes that the US Attorney's Office for the SDNY (specifically AUSAs Rohrbach, Pomerantz, Moe, and Comey) has been notified via email.
People (4)
| Name | Role | Context |
|---|---|---|
| Andrew Rohrbach | Assistant United States Attorney |
Recipient of email notification regarding the motion; representing the Appellee (SDNY).
|
| Lara Pomerantz | Assistant United States Attorney |
Recipient of email notification regarding the motion; representing the Appellee (SDNY).
|
| Alison Moe | Assistant United States Attorney |
Recipient of email notification regarding the motion; representing the Appellee (SDNY).
|
| Maureen Comey | Assistant United States Attorney |
Recipient of email notification regarding the motion; representing the Appellee (SDNY).
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States Attorney’s Office for the Southern District of New York |
The prosecuting office in the original trial, now the Appellee in this appeal.
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|
| The Court |
Implied Second Circuit Court of Appeals (based on Case 22-1426) receiving the request.
|
Locations (1)
| Location | Context |
|---|---|
|
Location of the US Attorney's Office.
|
Relationships (1)
Defense Counsel (Implied)
→
Opposing Counsel
→
Andrew Rohrbach, Lara Pomerantz, Alison Moe, Maureen Comey
Defense notified these AUSAs of their motion against the Appellee.
Key Quotes (4)
"The transcript is over 3000 pages and contains the allegations of multiple complainants."Source
DOJ-OGR-00020608.jpg
Quote #1
"In addition, we plan to raise issues pertaining to juror misconduct. This issue involves an exposition of facts and legal analysis pertaining to a juror questionnaire, voir dire, and a post-verdict hearing."Source
DOJ-OGR-00020608.jpg
Quote #2
"We also intend to raise issues pertaining to a non-prosecution agreement; certain instructions to the jury; and sentencing."Source
DOJ-OGR-00020608.jpg
Quote #3
"We request that the Court permit us to file a brief of no more than 20,000 words..."Source
DOJ-OGR-00020608.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,838 characters)
Case 22-1426, Document 43, 01/16/2023, 3452785, Page3 of 4
8. We request that the Court permit us to file a brief of no more than 20,000 words for the following reasons.
9. We plan to raise issues concerning evidentiary rulings by the trial court that we believe were erroneous. The rulings at issue require a detailed discussion of the evidence. The transcript is over 3000 pages and contains the allegations of multiple complainants. The legal issues cannot be raised by reference to a few discrete pages of the transcript; rather they go to cumulative prejudice resulting from the trial court’s erroneous application of the Federal Rules of Evidence to the case.
10. In addition, we plan to raise issues pertaining to juror misconduct. This issue involves an exposition of facts and legal analysis pertaining to a juror questionnaire, voir dire, and a post-verdict hearing. It is, in itself, its own mini-trial.
11. We also intend to raise issues pertaining to a non-prosecution agreement; certain instructions to the jury; and sentencing.
12. A motion to file an oversized brief must be made no less than 14 days before the brief is due. Local Rule 27.1(e)3. Thus, we make this motion now, although our motion to extend time to file our brief is pending.
13. We have notified Appellee United States Attorney’s Office for the Southern District of New York today, by email to Assistant United States Attorneys Andrew Rohrbach, Lara Pomerantz, Alison Moe, and Maureen Comey, that we are making this motion and have asked their position and if they intend to file a response. We have not received a reply as of the time of filing.
14. For the reasons stated, we respectfully request that the Court permit us to file a principal brief of no more than 20,000 words and would consent to Appellee filing a brief of
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DOJ-OGR-00020608
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