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Case 1:20-cr-00330-AJN Document 192 Filed 03/31/21 Page 3 of 3
LAW OFFICES OF BOBBI C. STERNHEIA\
Ms. Maxwell is entitled to a fair trial with effective assistance of counsel. If counsel feel
that additional time is required to guarantee those constitutional rights, Ms. Maxwell will suffer
the consequence by her continued detention. The Court has the power — and, indeed, the
discretion — to accommodate this constitutional clash. Granting a continuance and releasing Ms.
Maxwell on the most restrictive conditions of home detention. Surely, the Court can impose
conditions that “clip her wings” and satisfy perceived flight concerns without keeping Ms.
Maxwell locked in a BOP cage.
As counsel has notified the government, Ms. Maxwell is requesting an in-person
arraignment. She will not waive that right, most especially in light of media coverage and the
debacle that occurred during a remote proceeding in a related civil case before Judge Preska.
In addition, Ms. Maxwell is requesting a bail hearing at which witnesses will testify regarding
the purported strength of the government’s case. Further, we request that these proceedings be
scheduled to coincide with an evidence review session at the U.S. Attorney’s Office to be
attended by Ms. Maxwell with counsel.
Your consideration is greatly appreciated.
Very truly yours,
BOBBI C. STERNHEIM
cc: All counsel
DOJ-OGR-00002886
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| Filename | DOJ-OGR-00002886.jpg |
| File Size | 534.4 KB |
| OCR Confidence | 95.2% |
| Has Readable Text | Yes |
| Text Length | 1,391 characters |
| Indexed | 2026-02-03 16:28:12.248441 |