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efta-efta00089670DOJ Data Set 9Other

From: BOBBI C STERNHEIM <[email protected]>

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Unknown
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DOJ Data Set 9
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EFTA 00089670
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4
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From: BOBBI C STERNHEIM <[email protected]> To:'1 < Subject: Re: Ghislaine Maxwell (02879-509) Date: Mon, 02 Nov 2020 19:21:00 +0000 Thank you. BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Main: 212-243-1100 Cell: 917-912-9698 Fax: 888-587-4737 [email protected] "Covid-19 Notice: The %Vest 19th Street office is currently closed but we continue to work remotely. Please use email or fax, instead of regular mail, for all correspondence during this time. We continue to work regular business hours throughout this situation. Thank you for your consideration. Our best wishes for your good health and well being. This message and any attached documents contain information from the Law Offices of Bobbi C. Stemheim that may be confidential and/or privileged. If you are not the intended recipient, you may not read, copy, distribute, or use this information. If you have received this transmission in error, please

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EFTA Disclosure
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From: BOBBI C STERNHEIM <[email protected]> To: '1 < Subject: Re: Ghislaine Maxwell (02879-509) Date: Mon, 02 Nov 2020 19:21:00 +0000 Thank you. BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Main: 212-243-1100 Cell: 917-912-9698 Fax: 888-587-4737 [email protected] "Covid-19 Notice: The %Vest 19th Street office is currently closed but we continue to work remotely. Please use email or fax, instead of regular mail, for all correspondence during this time. We continue to work regular business hours throughout this situation. Thank you for your consideration. Our best wishes for your good health and well being. This message and any attached documents contain information from the Law Offices of Bobbi C. Stemheim that may be confidential and/or privileged. If you are not the intended recipient, you may not read, copy, distribute, or use this information. If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you. On Nov 2, 2020, at 11:05 AM, Bobbi, > wrote: This morning, I spoke with MDC legal counsel regarding the concerns you raised. MDC legal counsel conveyed the following: Within the last approximately 48 hours, MDC staff has conducted temperature checks in Ms. Maxwell's cell, all of which revealed that the temperature in Ms. Maxwell's cell was between 71 and 74 degrees. MDC legal counsel noted that the target temperature for the MDC during this season is 68 degrees. MDC staff also gave Ms. Maxwell an extra blanket, so she now has three blankets in her isolation cell. MDC staff physically entered Ms. Maxwell's cell and did not observe any smell or moisture. The unit team leader physically felt the papers in Ms. Maxwell's cell and observed that they felt normal and in no way damaged by moisture. MDC staff will ensure that Ms. Maxwell is able to bring a cup and a snack with her into her isolation cell. Please do not hesitate to reach out if any other issues or concerns arise. EFTA00089670 Best, Assistant United States Attorney Southern District of New York I St. Andrew's Plaza From: BOBBI C STERNHEIM <[email protected]> Sent: Sunday, November 1, 2020 1:50 PM To: Cc: aa; Subject: Re: Ghislaine Maxwell (02879-509) Thank you. Please keep me informed. Best- Bobbi BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Main: 212-243-1100 Cell: 917-912-9698 Fax: 888-587-4737 [email protected] (USANYS) This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be confidential and/or privileged. If you are not the intended recipient, you may not read, copy, distribute, or use this information. If you have received this transmission in error, please notO, the sender immediately by reply e-mail and then delete this message. Thank you. On Nov I, 2020, at 1:03 PM, Bobbi, > wrote: EFTA00089671 Thank you for reaching out regarding these concerns. I am forwarding your email to MDC legal counsel and will follow up to look into these issues. Please do not hesitate to reach out if any other concerns arise, and I will let you know when I have an update regarding the conditions in Ms. Maxwell's isolation cell. Assistant United States Attorney Southern District of New York I St. Andrew's Plaza kin..,Ve. le XIV I From: BOBBI C STERNHEIM <[email protected]> Sent: Sunday, November 1, 2020 12:41 PM To: Cc: < Subject: Ghislaine Maxwell (02879-509) >; > (USANYS) Good afternoon- I write to request immediate assistance for Ghislaine Maxwell. There are many conditions and restrictions placed upon her at the MDC that are of great complaint, but of immediate concern are conditions within Ms. Maxwell's isolation cell. The combination of cold, moisture, and sewage stench have made confinement in her cell unhealthy, unbearable, and utterly unreasonable. Her request for an extra blanket has been denied. Her request for use of her day mug for water has been denied. (She's been told to cup her hands to drink water from the faucet.) Her request to keep a snack in her cell has been denied. The moisture accumulating in her cell risks her health and the security of her legal work. You have known me and my reputation among your colleagues and the court. Trust me when I way that in my 35 years of federal criminal practice, having represented individuals charged and convicted of terrorism and capital murder, housed in MCC's 10South and FCI Florence-ADMAX (facilities I have visited), I have never witnessed such inappropriate and outlandish treatment of a non-violent pretrial detainee held on risk of flight. The mistreatment of Ghislaine Maxwell reflects negatively on your Office, the Court, and the BOP. The Government as a whole can and needs to do better. For today, we seek the bare minimum - a change of cell to a location that is safe from the cold, moisture, and stench, and an extra blanket to keep her warm. The rest will be left for another day. Please assist. Thank you- Bobbi EFTA00089672 BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Main: 212-243-1100 Cell: 917-912-9698 Fax: 888-587-4737 [email protected] ••Covid-19 Notice: The \Vest 19th Street office is currently closed but we continue to work remotely. Please use email or fax, instead of regular mail, for all correspondence during this time. We continue to work regular business hours throughout this situation. Thank you for your consideration. Our best wishes for your good health and well being. This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be confidential and/or privileged. If you are not the intended recipient, you may not read, copy, distribute, or use this information. If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you. EFTA00089673

Related Documents (6)

DOJ Data Set 9OtherUnknown

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Attorneys for Ghislaine Maxwell EFTA00090990 INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in United States for 30 years, has strong family ties and the support of friends and family residing in this country. She wants nothing more than to remain in the United States under whatever conditions the Court deems necessary so that she can effectively prepare fo

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U.S. Department of Justice United States Attorney Southern District of New York The Silvio I. Motto Building One Saint Andrew's Plaza New York. New York 10007 October 25, 2020 BY EMAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East Tenth Avenue Denver, CO 80203 Bobbi Sternheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: We write to disclose the attached notes and 302s, which are stam d SDNY_GM_00332929 through SDNY_GM_00332942, from interviews of Please note that the Government is designating the contents of this letter and its enclosures as "Confidential" under the Protective Order in this case. Very truly yours, AUDREY STRAUSS Acting United States Attorney by: s/ Assistant United States Attorneys (212

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120 LBUCmaxl UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. Before: 20 CR 330 (AJN) Jury Trial New York, N.Y. November 30, 2021 8:50 a.m. HON. ALISON J. NATHAN, APPEARANCES DAMIAN United States Attorney for the Southern District of New York BY: Assistant United States Attorneys HADDON MORGAN AND FOREMAN Attorneys for Defendant BY: JEFFREY S. PAGLIUCA CHRISTIAN R. EVERDELL LAURA A. MENNINGER -and- BOBBI C. STERNHEIM -and- RENATO STABILE Also Present: District Judge , FBI NYPD Sunny Drescher, Paralegal, U.S. Attorney's Office Ann Lundberg, Paralegal, Haddon Morgan and Foreman SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068582 121 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Jury not present) THE COURT: Looks like we have everybody. Matt

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UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA STIPULATION GHISLAINE MAXWELL, Defendant. x S2 20 CR 330 (AJN) IT IS HEREBY STIPULATED AND AGREED by and among the United States of America, by Damian Williams. United States Attorney for the Southern District of New York, and and Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christopher Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: 1. The document marked 3506-001 is a true and accurate copy of a transcript of the deposition taken on November 6, 2009 in West Palm Beach, Florida. EFTA00099019 2. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, marked as Government Exhibit 1006 may be received in evidence at trial. Dated: November 2021 New York, New York DAMIAN WILLIAMS United States Attorney for the Southern District of New York By: Ass

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA STIPULATION GHISLAINE MAXWELL, Defendant. x S2 20 CR 330 (AJN) IT IS HEREBY STIPULATED AND AGREED by and among the United States of America, by Damian Williams, United States Attorney for the Southern District of New York, and Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christopher Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: 1. The document marked 3504-009 is a true and accurate copy of the transcript of a sworn statement taken on November 21, 2005 in West Palm Beach, Florida. EFTA00090929 2. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, marked as Government Exhibit 1005, and the document marked 3504-009, may be received in evidence as Government exhibits at trial subject to objections by the defense based on relevance, hearsay, or under

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: Attorneys for Ghislaine Maxwell EFTA00083701 INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in United States for 30 years, has strong family ties and the support of friends and family residing in this

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