Case:de2016-00330-Au#h Document#:127021 Filed:08/23/21 Page:2 of 18
EXHIBIT A
DOJ-OGR-00020184
@epsteinpedia
CA:
AEb4NmMJF2x5kcp19M13RiXZuAGyajWSKLaioqBrpump
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
Full Text
Case:de2016-00330-Au#h Document#:127021 Filed:08/23/21 Page:2 of 18
EXHIBIT A
DOJ-OGR-00020184
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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.
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Individual Pages
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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.
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DOJ-OGR-00020183