DOJ-OGR-00002884.jpg
858 KB
Extraction Summary
4
People
3
Organizations
2
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal correspondence / letter to judge
File Size:
858 KB
Summary
A legal letter dated March 31, 2021, from attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The defense objects to a second superseding indictment filed by the government, characterizing it as 'tactical gamesmanship' that expands the conspiracy timeline (1994-2004) and adds charges based on old evidence against Jeffrey Epstein. Sternheim expresses concern over Maxwell's health and ability to stand trial, notes the government's refusal to provide accuser names, and requests a conference to discuss moving the July 12th trial date.
People (4)
| Name | Role | Context |
|---|---|---|
| Bobbi C. Sternheim | Defense Attorney |
Author of the letter representing Ghislaine Maxwell.
|
| Alison J. Nathan | United States District Judge |
Recipient of the letter.
|
| Ghislaine Maxwell | Defendant |
Subject of the criminal case and detention discussed in the letter.
|
| Jeffrey Epstein | Associate/Deceased |
Mentioned in context of evidence in government possession that was never used to charge him.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim |
Letterhead organization.
|
|
| United States District Court |
Court where the case is being heard.
|
|
| The Government |
Referenced regarding the filing of the superseding indictment and discovery issues.
|
Timeline (3 events)
1994-2004
Expanded time period of the conspiracy alleged in the new indictment.
N/A
2021-03-31
Filing of letter to Judge Nathan regarding superseding indictment.
New York, NY
Locations (2)
| Location | Context |
|---|---|
|
Address of Law Offices of Bobbi C. Sternheim.
|
|
|
Address of Judge Alison J. Nathan.
|
Relationships (2)
Sternheim writes on behalf of Maxwell regarding her defense.
Letter discusses charges related to a conspiracy involving Epstein and evidence previously held against him.
Key Quotes (4)
"That the government has made this move late in the game – with trial set for July 12th – is obvious tactical gamesmanship."Source
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Quote #1
"Adding charges that were never launched against Jeffrey Epstein based on evidence that was in the government’s possession for years is shocking, unfair, and an abuse of power."Source
DOJ-OGR-00002884.jpg
Quote #2
"The Court is aware of the extraordinary circumstances of Ms. Maxwell’s detention, its deleterious effect on her health and well-being, and the realistic concern whether she will be strong enough to withstand the stress of trial."Source
DOJ-OGR-00002884.jpg
Quote #3
"However, the government’s continued refusal to provide the most basic discovery – names of accusers – coupled with what amounts to a new indictment... has effectively prevented trial preparation from moving forward in an orderly manner."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,566 characters)
Case 1:20-cr-00330-AJN Document 192 Filed 03/31/21 Page 1 of 3
LAW OFFICES OF BOBBI C. STERNHEIM
212-243-1100 • Main
917-306-6666 • Cell
888-587-4737 • Fax
917-306-6666 • Cell
888-587-4737 • Fax
33 West 19th Street - 4th Floor
New York, New York 10011
bc@sternheimlaw.com
New York, New York 10011
bc@sternheimlaw.com
March 31, 2021
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
United States v. Ghislaine Maxwell
S2 20 Cr. 330 (AJN)
S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
This week’s filing of the second superseding indictment presents new and complicating issues. In addition to expanding a three-year conspiracy to 10 years, the government has added two serious charges that drastically change the focus of this case. That the government has made this move late in the game – with trial set for July 12th – is obvious tactical gamesmanship. Adding charges that were never launched against Jeffrey Epstein based on evidence that was in the government’s possession for years is shocking, unfair, and an abuse of power. More than doubling the time period of the originally charged conspiracy from 1994 to 2004 (previously 1997) and alleging two distinctly different substantive counts requires: additional investigation; requests for additional discovery; the need to supplement pretrial motions that have fully briefed and are pending before the Court; and the drafting and filing of additional motions pertinent to the new indictment. Accordingly, a new briefing schedule is required.
Even more concerning is the impact this late-breaking filing has on Ms. Maxwell’s constitutional rights. Her liberty interests now clash with her right to effective assistance of counsel. The Court is aware of the extraordinary circumstances of Ms. Maxwell’s detention, its deleterious effect on her health and well-being, and the realistic concern whether she will be strong enough to withstand the stress of trial.
Counsel have not yet determined whether to formally move for a continuance. This decision is not an easy one. Ms. Maxwell and her lawyers have been diligently preparing for trial. However, the government’s continued refusal to provide the most basic discovery – names of accusers – coupled with what amounts to a new indictment (after what was supposed to be the close of discovery and the resolution of very complicated legal issues) has effectively prevented trial preparation from moving forward in an orderly manner. Accordingly, we have requested an opportunity to confer with government counsel with the goal of clarifying the necessity of moving the trial date.
DOJ-OGR-00002884
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