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633 KB
Extraction Summary
5
People
6
Organizations
3
Locations
2
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal filing (conclusion page of a motion for bail)
File Size:
633 KB
Summary
This document is the conclusion page of a legal motion filed on March 16, 2021, requesting bail for Ghislaine Maxwell. It lists her defense team (Sternheim, Everdell, Pagliuca, Menninger) and includes a significant footnote detailing complaints about her confinement at the MDC. Specifically, the footnote alleges violations of attorney-client privilege during video conferences due to guard proximity and audio recording, as well as a denial of legal calls regarding pretrial motions.
People (5)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the bail request; currently incarcerated.
|
| Bobbi C. Sternheim | Attorney |
Defense counsel submitting the motion.
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| Christian R. Everdell | Attorney |
Defense counsel submitting the motion.
|
| Jeffrey S. Pagliuca | Attorney |
Defense counsel submitting the motion.
|
| Laura A. Menninger | Attorney |
Defense counsel submitting the motion.
|
Organizations (6)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim |
Representing Maxwell
|
|
| COHEN & GRESSER LLP |
Representing Maxwell
|
|
| HADDON, MORGAN & FOREMAN P.C |
Representing Maxwell
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| MDC |
Metropolitan Detention Center; where Maxwell is held.
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| BOP |
Bureau of Prisons; referenced regarding policy violations.
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|
| The Court |
SDNY (implied by case number AJN); recipient of the filing.
|
Timeline (2 events)
2021-03-16
Filing of Bail Motion Conclusion
New York (Court Filing)
Locations (3)
| Location | Context |
|---|---|
|
Address for Bobbi C. Sternheim
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Address for Cohen & Gresser LLP
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Address for Haddon, Morgan & Foreman P.C
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Relationships (2)
Signature block lists Sternheim as 'Attorneys for Ghislaine Maxwell'
Signature block lists Everdell as 'Attorneys for Ghislaine Maxwell'
Key Quotes (5)
"The Court should grant bail for Ms. Maxwell on the extraordinary conditions proposed."Source
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Quote #1
"confidential attorney-client communications conducted during video teleconferencing (VTC) are now further compromised by the repositioning of a camera with sensitive audio recording"Source
DOJ-OGR-00001265.jpg
Quote #2
"During VTC conferences, counsel can hear conversation among the guards, so it is likely that the guards... are able to hear discussions between Ms. Maxwell and counsel."Source
DOJ-OGR-00001265.jpg
Quote #3
"Last night... the MDC refused her request to speak with her lawyers"Source
DOJ-OGR-00001265.jpg
Quote #4
"Such denial violates the BOP’s Program Statement pertaining to providing legal calls upon request of pretrial inmates."Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (1,959 characters)
Case 1:20-cr-00330-AJN Document 172 Filed 03/16/21 Page 11 of 18
Conclusion
The Court should grant bail for Ms. Maxwell on the extraordinary conditions proposed. Should the Court determine that additional conditions are necessary, Ms. Maxwell is willing to satisfy and abide by those terms as well.
Dated: March 16, 2021
Respectfully submitted:
Bobbi C. Sternheim
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Phone: 212-243-1100
Bobbi C. Sternheim
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Phone: 212-243-1100
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Phone: 212-957-7600
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Phone: 212-957-7600
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C
150 East 10th Avenue
Denver, CO 80203
Phone: 303-831-7364
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C
150 East 10th Avenue
Denver, CO 80203
Phone: 303-831-7364
Attorneys for Ghislaine Maxwell
_________________________________________________________________
Maxwell’s guards and a hand-held camera focused on both Ms. Maxwell and counsel. Further, confidential attorney-client communications conducted during video teleconferencing (VTC) are now further compromised by the repositioning of a camera with sensitive audio recording, putting a chill on privileged communication. During VTC conferences, counsel can hear conversation among the guards, so it is likely that the guards, who seem to be writing during those sessions, are able to hear discussions between Ms. Maxwell and counsel. Last night, prior to the filing of defense replies to Ms. Maxwell’s pretrial motions, the MDC refused her request to speak with her lawyers to provide information bearing on those filings,. Such denial violates the BOP’s Program Statement pertaining to providing legal calls upon request of pretrial inmates. See https://www.bop.gov/policy/progstat/7331_004.pdf at par. 24(c). The chronic difficulties related to Ms. Maxwell’s review of the millions of documents of electronic discovery are continuing to negatively impact her ability to prepare for a trial that is only a few months away.
Maxwell’s guards and a hand-held camera focused on both Ms. Maxwell and counsel. Further, confidential attorney-client communications conducted during video teleconferencing (VTC) are now further compromised by the repositioning of a camera with sensitive audio recording, putting a chill on privileged communication. During VTC conferences, counsel can hear conversation among the guards, so it is likely that the guards, who seem to be writing during those sessions, are able to hear discussions between Ms. Maxwell and counsel. Last night, prior to the filing of defense replies to Ms. Maxwell’s pretrial motions, the MDC refused her request to speak with her lawyers to provide information bearing on those filings,. Such denial violates the BOP’s Program Statement pertaining to providing legal calls upon request of pretrial inmates. See https://www.bop.gov/policy/progstat/7331_004.pdf at par. 24(c). The chronic difficulties related to Ms. Maxwell’s review of the millions of documents of electronic discovery are continuing to negatively impact her ability to prepare for a trial that is only a few months away.
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