Letter: 20-cv-03306-AJN-OTW
Summary
The letter from Bobbi C. Sternheim expresses concerns about Ghislaine Maxwell's detention conditions at the MDC, citing the negative impact on her health and ability to prepare for trial. Sternheim argues that the MDC's overmanagement of Maxwell's detention is detrimental to her well-being. The letter is copied to counsel for all parties.
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Court Filing - Letter to Judge: 91
The letter from Bobbi C. Sternheim to Judge Alison J. Nathan responds to the MDC's letter regarding Ghislaine Maxwell's detention conditions, arguing that the conditions are harsh and restrictive, and not in response to any specific concerns related to Maxwell, but rather to the high-profile nature of the case and the BOP's previous failure to prevent Jeffrey Epstein's death.
Court Filing - Reply Memorandum: 103
This reply memorandum supports Ghislaine Maxwell's renewed motion for bail, arguing that the government's case relies heavily on the testimony of three witnesses without significant contemporaneous documentary evidence. Maxwell's defense presents a substantial bail package, including a bond secured by her and her spouse's assets and additional sureties, arguing that these conditions reasonably assure her appearance in court.
Letter: 12107-000038
The letter from Bobbi C. Sternheim describes the harsh conditions of Ghislaine Maxwell's detention, including being placed on suicide watch without justification and being held in de facto solitary confinement. Maxwell's health and well-being are suffering, affecting her ability to prepare for her defense. The letter criticizes the Bureau of Prisons' treatment of Maxwell as 'Pretrial Punishment'.
Court Filing - Memorandum in Support of Motion to Strike Surplusage: 146
Ghislaine Maxwell's defense team files a motion to strike surplusage from the superseding indictment, arguing that allegations regarding Accuser-3 are irrelevant, prejudicial, and should be stricken or subject to the admissibility requirements of Fed. R. Evid. 404(b). The memorandum contests the government's inclusion of Accuser-3's allegations, claiming they do not support the charges against Maxwell.
Court Filing - Letter to Judge: 192
The letter, written by defense attorney Bobbi C. Sternheim, objects to the government's filing of a second superseding indictment in the case against Ghislaine Maxwell, arguing it is an example of 'tactical gamesmanship' that complicates the case and prejudices Maxwell's rights. The defense requests a new briefing schedule and considers seeking a continuance, citing concerns about Maxwell's detention and right to a fair trial.
Court Filing - Letter to Judge: 272
The letter, written by Bobbi C. Sternheim, Maxwell's lawyer, to Judge Alison J. Nathan, disputes the government's claims about Maxwell's detention and highlights the MDC's alleged misconduct, including excessive surveillance, physical abuse, and failure to provide adequate care. The letter argues that Maxwell's detention conditions are detrimental to her health and ability to prepare for trial.
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