EFTA00024912.pdf
299 KB
Extraction Summary
6
People
3
Organizations
1
Locations
3
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal correspondence (email chain)
File Size:
299 KB
Summary
This document is an email chain between Ghislaine Maxwell's defense team (led by Bobbi Sternheim) and the US Government prosecutors regarding the scheduling of the trial start date in Case 20 Cr. 330. The defense argues strongly for a November 8, 2021 start date, citing Maxwell's health in detention and holiday conflicts, while the government proposes November 29, 2021, citing witness availability. The defense also leverages the scheduling dispute to suggest that granting Maxwell bail would resolve the flexibility issues.
People (6)
| Name | Role | Context |
|---|---|---|
| Bobbi C. Sternheim | Defense Attorney |
Lead counsel for Ghislaine Maxwell; negotiating trial dates with the government.
|
| Ghislaine Maxwell | Defendant |
Subject of the trial (US v. Maxwell); mentioned regarding health effects of detention and potential bail.
|
| Christian Everdell | Defense Attorney |
CC'd on emails; part of Maxwell's defense team.
|
| Laura Menninger | Defense Attorney |
CC'd on emails; noted to have a civil trial conflict on December 13th.
|
| Jeff Pagliuca | Defense Attorney |
CC'd on emails; part of Maxwell's defense team.
|
| Redacted Sender | Government Counsel (Prosecution) |
Representing the US Government/US Attorney's Office; proposing later trial dates.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim |
Firm representing the defendant.
|
|
| US District Court |
Implied authority overseeing the case (referenced as 'the Court').
|
|
| US Government |
The prosecution (referenced as 'the government').
|
Timeline (3 events)
2021-11-08
Proposed Trial Start Date (Defense Preference)
US District Court (SDNY)
2021-11-29
Proposed Trial Start Date (Government Preference)
US District Court (SDNY)
Locations (1)
| Location | Context |
|---|---|
|
Bobbi Sternheim's office (noted as closed due to Covid-19).
|
Relationships (3)
Sternheim represents Maxwell's interests regarding trial dates and bail.
Both on defense team; Sternheim notes Menninger's schedule conflicts.
Exchange of emails negotiating trial terms and dates.
Key Quotes (4)
"We are not able to agree to a November 8th trial date, given the need for continuity of counsel and the potential unavailability of a trial witness"Source
EFTA00024912.pdf
Quote #1
"Starting the trial on 11/29 - besides disrupting Thanksgiving holiday plans - will push the trial to the end of the year and possibly into the new year"Source
EFTA00024912.pdf
Quote #2
"These scheduling conflicts can be easily eliminated by consenting to bail for Ms. Maxwell."Source
EFTA00024912.pdf
Quote #3
"In light of Ms. Maxwell’s extended period of detention and its deleterious effect on her health and well-being, we cannot agree to a date far beyond 11/8."Source
EFTA00024912.pdf
Quote #4
Full Extracted Text
Complete text extracted from the document (10,752 characters)
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
[REDACTED BLACK BOX]
Law Offices of Bobbi C. Sternheim
[REDACTED BLACK BOX]
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
On May 10, 2021, at 6:00 PM, [REDACTED] wrote:
Hi Bobbi,
Thanks for following up. It seems that the parties agree about a November 2021 trial date but disagree about the week,
and we plan to file a letter this evening to that effect. We are not able to agree to a November 8th trial date, given the
need for continuity of counsel and the potential unavailability of a trial witness, but thank you for conferring with us
about this.
[REDACTED]
Hi Bobbi,
Thanks for following up. It seems that the parties agree about a November 2021 trial date but disagree about the week,
and we plan to file a letter this evening to that effect. We are not able to agree to a November 8th trial date, given the
need for continuity of counsel and the potential unavailability of a trial witness, but thank you for conferring with us
about this.
[REDACTED]
From: BOBBI C STERNHEIM [REDACTED]
Sent: Monday, May 10, 2021 5:34 PM
[REDACTED]
Cc: Christian Everdell [REDACTED]; Laura Menninger [REDACTED]; Jeff Pagliuca
Subject: US v. Maxwell -Trial Start Date
.
Good afternoon-
Following up on the status of our conferral emails as our joint letter (re: trial start date) is due today.
Thanks-
Bobbi
EFTA00024912
Sent: Monday, May 10, 2021 5:34 PM
[REDACTED]
Cc: Christian Everdell [REDACTED]; Laura Menninger [REDACTED]; Jeff Pagliuca
Subject: US v. Maxwell -Trial Start Date
.
Good afternoon-
Following up on the status of our conferral emails as our joint letter (re: trial start date) is due today.
Thanks-
Bobbi
EFTA00024912
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
[REDACTED BLACK BOX]
Law Offices of Bobbi C. Sternheim
[REDACTED BLACK BOX]
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
On May 9, 2021, at 12:14 PM, BOBBI C STERNHEIM [REDACTED] wrote:
Good afternoon-
In our 4/22 letter, we provided specific details concerning cases and trial dates
to justify our request for a continuance to 11/8.
Beyond a vague statement regarding consideration of availability of witnesses and counsel,
you have provided no specific details why the government cannot proceed to trial on 11/8.
Starting the trial on 11/29 - besides disrupting Thanksgiving holiday plans - will push the trial
to the end of the year and possibly into the new year, interfering with Christmas and
New Year’s plans, as COVID did last year. This will cast the defense and defense case
in a negative light as jurors impatiently wait for the trial to conclude before Christmas, which it won’t.
Our previous email explained our reasons for firmly pressing the 11/8 trial date,
but as an accommodation, we would consider starting on 11/15, but no later.
to justify our request for a continuance to 11/8.
Beyond a vague statement regarding consideration of availability of witnesses and counsel,
you have provided no specific details why the government cannot proceed to trial on 11/8.
Starting the trial on 11/29 - besides disrupting Thanksgiving holiday plans - will push the trial
to the end of the year and possibly into the new year, interfering with Christmas and
New Year’s plans, as COVID did last year. This will cast the defense and defense case
in a negative light as jurors impatiently wait for the trial to conclude before Christmas, which it won’t.
Our previous email explained our reasons for firmly pressing the 11/8 trial date,
but as an accommodation, we would consider starting on 11/15, but no later.
For now, we will not agree to exclusion of speedy trial time beyond 11/8.
These scheduling conflicts can be easily eliminated by consenting to bail for Ms. Maxwell.
These scheduling conflicts can be easily eliminated by consenting to bail for Ms. Maxwell.
It is unclear why the scheduling order, which contemplated a continuance, should be altered.
As previously discussed and raised with the Court, we need to review of 3500 material
and exhibits before determining the need to call any experts.
As previously discussed and raised with the Court, we need to review of 3500 material
and exhibits before determining the need to call any experts.
Enjoy the day.
Bobbi
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
[REDACTED]
EFTA00024913
Law Offices of Bobbi C. Sternheim
[REDACTED]
EFTA00024913
[REDACTED BLACK BOX]
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete
this message. Thank you.
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete
this message. Thank you.
On May 7, 2021, at 9:30 PM [REDACTED] wrote:
Bobbi,
Thanks very much for letting us know your availability. Regarding the trial date, after considering the availability of
witnesses and counsel, we plan to propose a trial date of November 29, 2021. Could you please let us know your
position regarding that date, so that we can include it in our letter to the Court? In addition, please let us know
whether you consent to an exclusion of time under the Speedy Trial Act between now and the new trial date the
Court selects.
witnesses and counsel, we plan to propose a trial date of November 29, 2021. Could you please let us know your
position regarding that date, so that we can include it in our letter to the Court? In addition, please let us know
whether you consent to an exclusion of time under the Speedy Trial Act between now and the new trial date the
Court selects.
With respect to other scheduling matters, we intend to propose that the Court set a deadline of three months before
trial for the Government to disclose the identities of victims referenced in the indictment; this is an earlier proposal
than the timeframe we had originally proposed for the July trial date. We also intend to propose that the deadline
for defense expert disclosures be set for two months before trial, given the substantial length of the adjournment.
Please let us know your position regarding those proposed dates and we'll include it in our letter.
trial for the Government to disclose the identities of victims referenced in the indictment; this is an earlier proposal
than the timeframe we had originally proposed for the July trial date. We also intend to propose that the deadline
for defense expert disclosures be set for two months before trial, given the substantial length of the adjournment.
Please let us know your position regarding those proposed dates and we'll include it in our letter.
Thanks very much, and hope everyone has a nice weekend--
[REDACTED]
From: BOBBI C STERNHEIM [REDACTED]
Sent: Friday, May 7, 2021 5:26 PM
[REDACTED]
Christian Everdell <[REDACTED]>; Laura
Menninger [REDACTED]; Jeff Pagliuca [REDACTED]
Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Sent: Friday, May 7, 2021 5:26 PM
[REDACTED]
Christian Everdell <[REDACTED]>; Laura
Menninger [REDACTED]; Jeff Pagliuca [REDACTED]
Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
[REDACTED]
We are available to begin November 8th and to conclude by the end of the year.
EFTA00024914
We are available to begin November 8th and to conclude by the end of the year.
EFTA00024914
Laura has a civil trial scheduled for December 13th, but will try to move it.
Bobbi
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
[REDACTED BLACK BOX]
Law Offices of Bobbi C. Sternheim
[REDACTED BLACK BOX]
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete
this message. Thank you.
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete
this message. Thank you.
On May 7, 2021, at 5:16 PM [REDACTED] wrote:
Bobbi,
Bobbi,
We understand that you’re requesting a November 8th date, and that you prefer that date. Separate from your
preferences, our question was simply about your scheduling availability in light of the Court’s order. Can you please
let us know your availability and we will note that accordingly in our submission to the Court?
preferences, our question was simply about your scheduling availability in light of the Court’s order. Can you please
let us know your availability and we will note that accordingly in our submission to the Court?
[REDACTED]
From: BOBBI C STERNHEIM [REDACTED]
Sent: Friday, May 7, 2021 4:00 PM
[REDACTED]
Cc: Christian Everdell <[REDACTED]>; Laura Menninger <[REDACTED]>; Jeff Pagliuca
[REDACTED]
Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Sent: Friday, May 7, 2021 4:00 PM
[REDACTED]
Cc: Christian Everdell <[REDACTED]>; Laura Menninger <[REDACTED]>; Jeff Pagliuca
[REDACTED]
Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Good afternoon-
For the reasons stated in our letter-motion of 4/22 (Dkt. 246),
our earliest and preferred date in the fall is 11/8.
In light of Ms. Maxwell’s extended period of detention
and its deleterious effect on her health and well-being,
EFTA00024915
For the reasons stated in our letter-motion of 4/22 (Dkt. 246),
our earliest and preferred date in the fall is 11/8.
In light of Ms. Maxwell’s extended period of detention
and its deleterious effect on her health and well-being,
EFTA00024915
we cannot agree to a date far beyond 11/8.
However, should you agree to her release pending trial,
we would have greater date flexibility.
Enjoy the weekend.
Bobbi
However, should you agree to her release pending trial,
we would have greater date flexibility.
Enjoy the weekend.
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
[REDACTED BLACK BOX]
Law Offices of Bobbi C. Sternheim
[REDACTED BLACK BOX]
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
On May 7, 2021, at 1:13 PM, [REDACTED] wrote:
Hi Bobbi,
Thanks for your response. Your April 22, 2021 letter does not address the defense’s availability for trial dates after
November 8th, and it would be helpful to get a complete picture of available dates throughout the balance of
2021 in order to provide the Court with comprehensive information. We’re still in the process of conferring with
witnesses regarding their availability, so we’re gathering a variety of data points. Please let us know your
availability and we can put together a proposal.
November 8th, and it would be helpful to get a complete picture of available dates throughout the balance of
2021 in order to provide the Court with comprehensive information. We’re still in the process of conferring with
witnesses regarding their availability, so we’re gathering a variety of data points. Please let us know your
availability and we can put together a proposal.
Thanks,
[REDACTED]
From: BOBBI C STERNHEIM [REDACTED]
Sent: Thursday, May 6, 2021 11:58 PM
EFTA00024916
Sent: Thursday, May 6, 2021 11:58 PM
EFTA00024916
Cc: Christian Everdell <[REDACTED]>; Laura Menninger [REDACTED]; Jeff
Pagliuca [REDACTED]
Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Pagliuca [REDACTED]
Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Good evening-
Our 4/22 letter detailed our position. Please let us know your availability for 11/8.
Thank you-
Bobbi
Our 4/22 letter detailed our position. Please let us know your availability for 11/8.
Thank you-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
[REDACTED BLACK BOX]
Law Offices of Bobbi C. Sternheim
[REDACTED BLACK BOX]
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then
delete this message. Thank you.
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then
delete this message. Thank you.
On May 6, 2021, at 7:15 PM [REDACTED] wrote:
Counsel,
We write to confer in accordance with the Court’s Order about a trial date in this case. Please let us know your
preferences and availability for trial dates from September 2021 through the end of the year. If you could please
provide details for any conflicts, that would be helpful.
preferences and availability for trial dates from September 2021 through the end of the year. If you could please
provide details for any conflicts, that would be helpful.
Thank you,
EFTA00024917
EFTA00024917
[REDACTED BLACK BOX]
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EFTA00024918
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EFTA00024918
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