Letter: 12107-000038
Summary
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'.
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Related Documents (6)
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.
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.
Letter: 20-cv-03306-AJN-OTW
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.
Court Filing - Memorandum of Law: 342
The document is a memorandum of law in support of Ghislaine Maxwell's motion for individual sequestered juror voir dire and limited counsel-conducted voir dire. It argues that due to extensive pretrial publicity and sensitive subject matter, a standard voir dire is insufficient and that individual sequestered voir dire is necessary to root out potential juror bias.
Court Filing - Letter: 384-1
The document is a letter from the United States Attorney's Office to defense attorneys, informing them that the government intends to refer to Jeffrey Epstein as a co-conspirator of Ghislaine Maxwell at trial. The government has produced co-conspirator statements and will continue to do so as part of its ongoing obligations. The letter is designated as 'confidential' under the Protective Order in the case.
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