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Document 2016-00330

AI Analysis

Summary: The document is a court filing related to Ghislaine Maxwell's bail request, highlighting issues with attorney-client privilege due to compromised video teleconferencing and difficulties with reviewing electronic discovery. The filing requests the court to grant bail under proposed conditions. The attorneys for Ghislaine Maxwell submitted the filing on March 16, 2021.
Significance: This document is potentially important as it reveals concerns about the violation of Ghislaine Maxwell's attorney-client privilege and her ability to prepare for trial due to difficulties with electronic discovery review.
Key Topics: Ghislaine Maxwell's bail request Attorney-client privilege concerns Challenges with electronic discovery review
Key People:
  • Ghislaine Maxwell - Defendant
  • Bobbi C. Sternheim - Attorney for Ghislaine Maxwell
  • Christian R. Everdell - Attorney for Ghislaine Maxwell
  • Jeffrey S. Pagliuca - Attorney for Ghislaine Maxwell
  • Laura A. Menninger - Attorney for Ghislaine Maxwell
Document Type
Exhibit
Date
Unknown
Pages
2
Folder
IMAGES007

Full Text

Case:de2016-00330-Au#h Document#:127021 Filed:08/23/21 Page:2 of 18 EXHIBIT A DOJ-OGR-00020184 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 112 Filed 03/23/21 Page 11 of 18 Conclusion The Court should grant bail for Ms. Maxwell on the extraordinary conditions proposed. Should the Court determine that additional conditions are necessary, Ms. Maxwell is willing to satisfy and abide by those terms as well. Dated: March 16, 2021 Respectfully submitted: Bobbi C. Sternheim Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 Attorneys for Ghislaine Maxwell Maxwell's guards and a hand-held camera focused on both Ms. Maxwell and counsel. Further, confidential attorney-client communications conducted during video teleconferencing (VTC) are now further compromised by the repositioning of a camera with sensitive audio recording, putting a chill on privileged communication. During VTC conferences, counsel can hear conversation among the guards, so it is likely that the guards, who seem to be writing during those sessions, are able to hear discussions between Ms. Maxwell and counsel. Last night, prior to the filing of defense replies to Ms. Maxwell's pretrial motions, the MDC refused her request to speak with her lawyers to provide information bearing on those filings. Such denial violates the BOP's Program Statement pertaining to providing legal calls upon request of pretrial inmates. See https://www.bop.gov/policy/progstat/7331_004.pdf at par. 24(c). The chronic difficulties related to Ms. Maxwell's review of the millions of documents of electronic discovery are continuing to negatively impact her ability to prepare for a trial that is only a few months away. 10 DOJ-OGR-00020183

Individual Pages

Page 2 - DOJ-OGR-00020184
Case:de2016-00330-Au#h Document#:127021 Filed:08/23/21 Page:2 of 18 EXHIBIT A DOJ-OGR-00020184
Page 11 - DOJ-OGR-00020183
Case 1:20-cr-00330-AJN Document 112 Filed 03/23/21 Page 11 of 18 Conclusion The Court should grant bail for Ms. Maxwell on the extraordinary conditions proposed. Should the Court determine that additional conditions are necessary, Ms. Maxwell is willing to satisfy and abide by those terms as well. Dated: March 16, 2021 Respectfully submitted: Bobbi C. Sternheim Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 Attorneys for Ghislaine Maxwell Maxwell's guards and a hand-held camera focused on both Ms. Maxwell and counsel. Further, confidential attorney-client communications conducted during video teleconferencing (VTC) are now further compromised by the repositioning of a camera with sensitive audio recording, putting a chill on privileged communication. During VTC conferences, counsel can hear conversation among the guards, so it is likely that the guards, who seem to be writing during those sessions, are able to hear discussions between Ms. Maxwell and counsel. Last night, prior to the filing of defense replies to Ms. Maxwell's pretrial motions, the MDC refused her request to speak with her lawyers to provide information bearing on those filings. Such denial violates the BOP's Program Statement pertaining to providing legal calls upon request of pretrial inmates. See https://www.bop.gov/policy/progstat/7331_004.pdf at par. 24(c). The chronic difficulties related to Ms. Maxwell's review of the millions of documents of electronic discovery are continuing to negatively impact her ability to prepare for a trial that is only a few months away. 10 DOJ-OGR-00020183