LAW OFFICES OF BOBBI C. STERNHEIM
Summary
LAW OFFICES OF BOBBI C. STERNHEIM Mole Cell Fax VIA Email Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 Dear Judge Nathan: 33 West 19th Street - 4th Floor New York, New York 10011 April 13, 2021 Re: United States v. Ghislaine S2 20 Cr. 330 (AJN) I write to request that Court sign the attached proposed order directing the U.S. Marshal to permit Ghislaine Maxwell to have access to her legal papers while in the cellblock at 500 Pearl Street awaiting the evidence review being conducted in the U.S. Attorney's Office on the 5th floor. Today, she arrived at the courthouse at approximately 5:15 am and remained idle in the cellblock until approximately 8:30 am when she was brought to the to the evidence review. Ms. Maxwell will be attending the evidence review throughout this week. Your consideration is greatly appreciated. Very truly yours, gat.g C. 51.04-4:44. BOBBI C. STERNHEIM Enc. cc: All couns
Persons Referenced (4)
Tags
Search 264K+ documents with AI-powered analysis
Extracted Text (OCR)
EFTA DisclosureRelated Documents (6)
From: '
From: ' y• < To: BOBBI Cc:' Subject: RE: Ghislaine Maxwell 02879-509 Date: Mon, 16 Nov 2020 18:06:58 +0000 (USANYS)" Bobbi, Thank you for including me on this email. I understand from my conversation with MDC legal counsel today that MDC staff is continuing to monitor temperatures throughout the facility, including in the area where Ms. Maxwell is housed. My understanding is that the temperature where Ms. Maxwell is housed remains within the limits prescribed by BOP policy and that the MDC does not expect this week's activities to affect the temperature in Ms. Maxwell's cell. That said, they will continue to monitor the temperature and take appropriate action if it falls below prescribed limits. As has previously been conveyed via letter from the Government to defense counsel dated October 8, 2020, the MDC's assessment continues to be that Ms. Maxwell's current cell is the most appropriate placement for Ms. Maxwell both for her safety and the security of the institution.
U.S. Department of Justice
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 20, 2020 BY ELECTRONIC MAIL 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. Sternheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: In recognition of the Government's ongoing discovery obligations, today we are producing copies of the materials listed in the below index, which materials are stamped with control numbers SDNY_GM_00328070 through SDNY_GM_00356148. The password for the drive is "USAOsdnyl!". The materials are available for pickup at the U.S. Attorney's Office in Manhattan. Please note that both this l
LAW OFFICES OF BOBBI C. STERNHEIM
LAW OFFICES OF BOBBI C. STERNHEIM Main Cell Fax VIA Email Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 Dear Judge Nathan: 33 West 19th Street - 4th Floor New York, New York 10011 April 13, 2021 Re: United States v. Ghislaine S2 20 Cr. 330 (AJN) I write to request that Court sign the attached proposed order directing the U.S. Marshal to permit Ghislaine Maxwell to have access to her legal papers while in the cellblock at 500 Pearl Street awaiting the evidence review being conducted in the U.S. Attorney's Office on the 5th floor. Today, she arrived at the courthouse at approximately 5:15 am and remained idle in the cellblock until approximately 8:30 am when she was brought to the to the evidence review. Ms. Maxwell will be attending the evidence review throughout this week. Your consideration is greatly appreciated. Very truly yours, gOuz C. Stunda.:m. BOBBI C. STERNHEIM Enc. cc: All counsel
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, : 20 Cr. 330 (MN) v. GHISLAINE MAXWELL, Defendant. • • x GHISLAINE MAXWELL'S MOTION TO SUPPRESS IDENTIFICATION Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver Phone: Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 225 Broadway, Suite 715 New York NY 10007 Phone: Attorneys for Chislaine Maxwell EFTA00090466 TABLE OF CONTENTS BACKGROUND 1 ARGUMENT 2 i EFTA00090467 TABLES OF AUTHORITIES Cases Manson v. Brathwaite, 432 U.S. 98 (1977) 2, 3 Neil v. Biggers, 409 U.S. 188 (1972) 2, 3 Raheem v. Kelly, 257 F.3d 122 (2d Cir. 2001) 3 Simmons v. United States, 390 U.S. 377 (1968) 2, 3 Stovall v. Demo, 388 U.S. 293 (1967) 2 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992) 3 United States v. Hemmings, 482 F. App'x 640
LBUCmaxl
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
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 OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION FOR A SEVERANCE OF AND SEPARATE TRIAL ON COUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00091875 TABLE OF CONTENTS TABLE OF CONTENTS TABLE OF AUTHORITIES ii INTRODUCTION 1 OVERVIEW OF THE ALLEGATIONS 2 A. Counts One through Four (the "Mann Act Counts") 2 B. Counts Five and Six (the "Perjury Counts") 2 APPLICABLE LAW 3 A. Joinder of Offenses 3 B. Sev
Forum Discussions
This document was digitized, indexed, and cross-referenced with 1,400+ persons in the Epstein files. 100% free, ad-free, and independent.