| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
GHISLAINE MAXWELL
|
Legal representative |
6
|
1 | |
|
person
Bobbi C. Sternheim
|
Professional employment |
6
|
1 |
This document is a letter dated October 13, 2021, from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense team. The Government asserts that Maxwell has waived her right to use an insanity or mental condition defense (Rule 12.2) because she failed to provide notice by the pretrial motion deadlines in early 2021. The letter demands that if the defense intends to use such evidence despite the waiver, they must provide notice by October 20, 2021.
This document is a legal memorandum filed on October 13, 2021, by Ghislaine Maxwell's defense team in the Southern District of New York. The defense argues that due to 'tsunami' of negative pretrial publicity surrounding Maxwell and Jeffrey Epstein (including books, podcasts, and documentaries), standard jury selection is insufficient. They request the Court allow individual sequestered voir dire and limited attorney-conducted questioning to identify and remove biased jurors.
This document is an email thread from October 2021 regarding the 'US v. Maxwell' case (Ghislaine Maxwell). The correspondence is between the Judge's chambers (Hon. Alison J. Nathan), Defense Counsel (Bobbi C. Sternheim), and the US Attorney's Office. The discussion concerns the filing of a Joint Proposed Juror Questionnaire, requests to seal documents, and the Court's request for copies of Jencks Act material (evidence regarding government witnesses).
This document is a legal memorandum filed on October 13, 2021, by Ghislaine Maxwell's defense team in the Southern District of New York. The defense argues for individual sequestered voir dire (jury selection questioning) and permission for attorneys to conduct limited questioning of jurors, citing 'tsunami' levels of negative pretrial publicity and the inflammatory nature of the sexual abuse charges. The motion lists numerous documentaries, podcasts, and books as evidence of prejudicial media coverage that allegedly demonizes Maxwell and links her inextricably to Jeffrey Epstein's crimes.
This document is an email thread from November 2020 involving Bobbi C. Sternheim, defense attorney for Ghislaine Maxwell. Sternheim writes to BOP officials stating that Maxwell (Inmate 02879-509) has been placed in quarantine after contact with a COVID-infected corrections officer. Sternheim requests that previously scheduled in-person legal visits for November 21 and November 28 be converted to legal calls to discuss time-sensitive matters.
A discovery letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team dated November 11, 2021. The letter details the production of 'Amazon records' (Bates SDNY_GM_02771981-02771983) which were sourced from the U.S. Attorney's Office for the Southern District of Florida and potentially duplicate materials previously produced from the Florida FBI file.
A letter dated November 16, 2021, from US Attorney Damian Williams to Ghislaine Maxwell's defense team. The letter accompanies the production of Jencks Act and Giglio materials for potential trial witnesses, as well as materials related to individuals the government does not currently intend to call. It specifies that these materials are subject to a protective order and explains the specific labeling used to distinguish them from classified documents.
This document is a letter dated November 16, 2021, from U.S. Attorney Damian Williams to the defense counsel for Ghislaine Maxwell. It serves as a cover letter for the production of discovery materials, specifically AT&T records, phone records, and photographs, noting that these materials are subject to a protective order.
This document is a discovery letter dated November 9, 2021, from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense team. It details the production of 'SDFL Files' (likely Southern District of Florida files) with Bates numbers SDNY_GM_02767074 through SDNY_GM_02771980. The letter notes these materials are confidential under a protective order and appear to be duplicative of previous discovery.
A discovery letter dated November 9, 2021, from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense team. The letter accompanies the production of 'Business Records from SDFL Files' (Bates SDNY_GM_02767074 - 02771980), which the government notes are likely duplicative of materials previously produced from Florida FBI files in 2020. The letter also clarifies confidentiality designations under the Protective Order.
An email dated November 9, 2021, from attorney Bobbi C. Sternheim to redacted recipients and co-counsel (Everdell, Menninger, Pagliuca). The email serves to provide a courtesy copy of an ECF filing ('Reply_to_Dkt_423.pdf') related to the case U.S. v. Maxwell (S2 20 Cr. 330) and to update recipients on Sternheim's new office address, which is redacted in the document.
An email dated November 8, 2021, from attorney Bobbi C. Sternheim regarding the U.S. v. Maxwell case (S2 20 Cr. 330). The email serves as a courtesy copy of an ECF filing (referenced as 'fling') related to an attachment titled 'Suggestion_to_Dkt_404.pdf' and provides notice of Sternheim's new office address. Recipients include co-counsel Christian Everdell, Laura Menninger, and Jeff Pagliuca.
This document is an email chain between Ghislaine Maxwell's defense attorney, Bobbi Sternheim, and the US Attorney's Office (SDNY) regarding conditions at the Metropolitan Detention Center (MDC) in November 2020. Sternheim requests Maxwell be moved to an interior cell due to reports that the NYC Dept. of Design & Construction would be shutting off heat and water overnight for repairs. The Assistant US Attorney denies the request, stating that temperatures are being monitored and remain within BOP policy limits, and asserting that Maxwell's current placement is appropriate for safety and security.
This document is an email from attorney Bobbi C. Sternheim regarding the confinement conditions of Ghislaine Maxwell on April 13, 2021. Sternheim inquires if the recipient can persuade the Marshal to allow Maxwell access to legal materials while in the cell block, noting that Maxwell sat idle for over three hours that morning. Sternheim suggests she may seek a Court order if the issue cannot be resolved.
This document is the signature page (page 5 of 5) of a legal filing dated December 15, 2021, addressed to Judge Alison J. Nathan in the case regarding Ghislaine Maxwell. It lists the contact information and signatures of Maxwell's defense attorneys: Jeffrey S. Pagliuca, Laura A. Menninger, Christian R. Everdell, and Bobbi C. Sternheim.
This document is the third and final page of a legal filing (Document 553) in case 1:20-cr-00330-PAE, dated December 15, 2021, and filed on December 17, 2021. It serves as the signature page for a letter or motion addressed to The Honorable Alison J. Nathan from the legal team representing Ghislaine Maxwell, including attorneys Jeffrey S. Pagliuca, Laura A. Menninger, Christian R. Everdell, and Bobbi C. Sternheim. The document also indicates that a copy was sent via email to the counsel of record.
A legal letter from defense attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the trial of Ghislaine Maxwell. The letter argues that the government used suggestive questioning techniques on accusers, specifically citing an instance where a witness named 'Jane' changed her testimony regarding a trip to New York and seeing 'The Lion King' after pressure from AUSA Rossmiller. The defense uses this to justify the necessity of expert testimony from Dr. Loftus regarding memory and suggestive questioning.
This document is the final page of a legal filing (Document 544) from December 13, 2021, addressed to Judge Alison J. Nathan. Attorneys for Ghislaine Maxwell assert her constitutional right to call Mr. Scarola, Mr. Edwards, and Mr. Glassman as witnesses. The page includes the contact information for her legal counsel from three different law firms.
This is a legal letter dated December 12, 2021, from defense attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. Sternheim informs the court of logistical issues with defense witnesses, including travel from abroad, and notifies the judge that three witnesses have requested to testify under pseudonyms. The letter states that the government opposes this request and warns that the court's ruling could compromise Maxwell's right to present her defense.
This document is the signature page (page 5 of 5) of a legal filing, Document 521, in case 1:20-cr-00330-PAE, dated December 3, 2021. It is respectfully submitted to The Honorable Alison J. Nathan by the legal team representing Ghislaine Maxwell, which includes attorneys Jeffrey S. Pagliuca, Laura A. Menninger, Christian R. Everdell, and Bobbi C. Sternheim from three different law firms.
This document is the final page of a legal letter dated December 7, 2020, from attorney Bobbi C. Sternheim. The letter requests the immediate elimination of 'onerous' and 'restrictive' detention conditions for her client, Ms. Maxwell. Copies of the letter were sent via email to four other attorneys involved in the case.
This legal document, filed on behalf of Ms. Maxwell, details her alleged mistreatment while in custody at the MDC. The filing outlines several issues, including invasive physical searches that increase her COVID-19 risk, severe deprivation of adequate and nutritious food leading to significant weight loss and health problems, and sleep deprivation due to constant checks with flashlights. These conditions are presented as negatively impacting her health and her ability to prepare for her legal defense.
This legal document, a letter from the law office of Bobbi C. Sternheim, argues that their client, Ghislaine Maxwell, is being subjected to "draconian" and punitive pretrial detention conditions. The letter posits that these harsh measures are not related to Maxwell's own conduct but are a direct result of the government's attempt to repair its reputation following the suicide of Jeffrey Epstein in federal custody. The attorney details failed attempts to resolve these issues through internal prison channels and claims the conditions are impeding Maxwell's ability to prepare her legal defense.
This document is page 3 of a legal filing by attorney Bobbi C. Sternheim on behalf of Ghislaine Maxwell, dated December 7, 2020. The letter argues that Maxwell is facing unduly harsh conditions, including solitary isolation, as a result of the Bureau of Prisons' incompetence and embarrassment over Jeffrey Epstein's suicide. Sternheim asserts that Maxwell is an 'exemplary detainee' and calls for Warden Tellez to address the concerns regarding her confinement, which are allegedly interfering with her legal defense.
This legal document, filed by the law office of Bobbi C. Sternheim on behalf of Ms. Maxwell, argues against the restrictive conditions of her confinement at the Metropolitan Detention Center (MDC). The filing contends that these measures, including constant surveillance and repeated searches, are an overreaction to the BOP's failure to prevent Jeffrey Epstein's death, rather than being based on any specific risk posed by Maxwell. The document also raises concerns about Ms. Maxwell's exposure to COVID-19 and the erasure of her legal emails, quoting then-Attorney General William Barr's stated interest in ensuring she makes it to trial.
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