DOJ-OGR-00005620.jpg
509 KB
Extraction Summary
5
People
5
Organizations
3
Locations
3
Events
4
Relationships
3
Quotes
Document Information
Type:
Legal filing (motion/response signature page)
File Size:
509 KB
Summary
This document is the signature page (Page 11 of 12) of a legal filing submitted on October 18, 2021, by the defense team for Ghislaine Maxwell. The attorneys argue that the Government failed to comply with Rule 404(b) notice deadlines (originally May 28, extended to October 11), depriving Maxwell of the chance to litigate properly, and they request the Court exclude this belated evidence. The document lists the contact information for defense attorneys from three different law firms.
People (5)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the legal defense; attorneys arguing she was deprived of opportunity to litigate issues.
|
| Jeffrey S. Pagliuca | Attorney |
Signatory; Attorney for Ghislaine Maxwell.
|
| Laura A. Menninger | Attorney |
Signatory; Attorney for Ghislaine Maxwell.
|
| Christian R. Everdell | Attorney |
Signatory; Attorney for Ghislaine Maxwell.
|
| Bobbi C. Sternheim | Attorney |
Signatory; Attorney for Ghislaine Maxwell.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| HADDON, MORGAN & FOREMAN P.C. |
Firm representing Maxwell (Pagliuca/Menninger).
|
|
| COHEN & GRESSER LLP |
Firm representing Maxwell (Everdell).
|
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| Law Offices of Bobbi C. Sternheim |
Firm representing Maxwell (Sternheim).
|
|
| The Government |
Opposing party in the case.
|
|
| DOJ |
Department of Justice (indicated by Bates stamp DOJ-OGR).
|
Timeline (3 events)
Locations (3)
| Location | Context |
|---|---|
|
Address for Haddon, Morgan & Foreman P.C.
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|
|
Address for Cohen & Gresser LLP.
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Address for Law Offices of Bobbi C. Sternheim.
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Relationships (4)
Listed as 'Attorneys for Ghislaine Maxwell'
Listed as 'Attorneys for Ghislaine Maxwell'
Listed as 'Attorneys for Ghislaine Maxwell'
Listed as 'Attorneys for Ghislaine Maxwell'
Key Quotes (3)
"The failure to comply with the requirements of the Rule has deprived Ms. Maxwell of the opportunity to litigate the issues on the timetable set by the Court."Source
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Quote #1
"This Court should exclude any evidence the government seeks belatedly to offer pursuant to Rule 404(b)"Source
DOJ-OGR-00005620.jpg
Quote #2
"There is thus no 'good cause' for extending the Government's ability to do so."Source
DOJ-OGR-00005620.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,295 characters)
Case 1:20-cr-00330-PAE Document 385 Filed 10/29/21 Page 11 of 12
404(b) Notice by May 28, a date that was extended to October 11 after the continuance of the
trial. Dkt. 229 at 3. The failure to comply with the requirements of the Rule has deprived Ms.
Maxwell of the opportunity to litigate the issues on the timetable set by the Court. There is thus
no "good cause" for extending the Government's ability to do so. This Court should exclude any
evidence the government seeks belatedly to offer pursuant to Rule 404(b), or, alternatively
should the Court find good cause for the failure of notice, grant Ms. Maxwell additional time to
respond. As far as admissibility of the evidence referenced in the Letter as "direct evidence" of
the charged crimes, Ms. Maxwell seeks leave to file such a Motion within two weeks.
trial. Dkt. 229 at 3. The failure to comply with the requirements of the Rule has deprived Ms.
Maxwell of the opportunity to litigate the issues on the timetable set by the Court. There is thus
no "good cause" for extending the Government's ability to do so. This Court should exclude any
evidence the government seeks belatedly to offer pursuant to Rule 404(b), or, alternatively
should the Court find good cause for the failure of notice, grant Ms. Maxwell additional time to
respond. As far as admissibility of the evidence referenced in the Letter as "direct evidence" of
the charged crimes, Ms. Maxwell seeks leave to file such a Motion within two weeks.
Dated: October 18, 2021
Respectfully submitted,
s/ Jeffrey S. Pagliuca
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303-831-7364
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303-831-7364
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
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
Phone: 212-243-1100
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
Phone: 212-243-1100
Attorneys for Ghislaine Maxwell
8
DOJ-OGR-00005620
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