EFTA00096049.pdf

From: To: BOBBI C STERNHEIM Cc: Christian Everdell , Laura Menninger Jeff Pagliuca Subject: RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Date: Fri, 07 May 2021 21:16:21 +0000 Bobbi, We understand that you're requesting a November 8th date, and that you prefer that date. Separate from your preferences, our question was simply about your scheduling availability in light of the Court's order. Can you please let us know your availability and we will note that accordingly in our submission to the Court? From: BOBBI C STERNHEIM Sent: Friday, May 7, 20214:00 PM To: (US Cc: Christian Everdell Laura Menninger Jeff Pagliuca Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Good afternoon- For the reasons stated in our letter-motion of 4/22 (Dkt. 246), our earliest and preferred date in the fall is 11/8. In light of Ms. Maxwell's extended period of detention and its deleterious effect on her health and well-being, we cannot agree to a date far beyond 11/8. However, should you agree to her release pending trial, we would have greater date flexibility. Enjoy the weekend. Bobbi BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Sternheim • •Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely. Please use email or fax, instead of regular mail, for all correspondence during this time. We continue to work regular business hours throughout this situation. EFTA00096049 Thank you for your consideration. Our best wishes for your good health and well being. This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be confidential and/or privileged. If you are not the intended recipient, you may not read, copy, distribute, or use this information. If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you. On May 7, 2021, at 1:13 PM Hi Bobbi, wrote: Thanks for your response. Your April 22, 2021 letter does not address the defense's availability for trial dates after November 8th, and it would be helpful to get a complete picture of available dates throughout the balance of 2021 in order to provide the Court with comprehensive information. We're still in the process of conferring with witnesses regarding their availability, so we're gathering a variety of data points. Please let us know your availability and we can put together a proposal. Thanks, From: BOBBI C STERNHEIM Sent: Thursday, May 6, 2021 11:58 PM To: (U Cc: Christian Everdell Laura Menninger ; Jeff Pagliuca Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Good evening- Our 4/22 letter detailed our position. Please let us know your availability for 11/8. Thank you- Bobbi BOBBI C. STERNHEIM, ESQ. EFTA00096050 This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be confidential and/or privileged. If you are not the intended recipient, you may not read, copy, distribute, or use this information. If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you. On May 6, 2021, at 7:15 PM Counsel, wrote: We write to confer in accordance with the Court's Order about a trial date in this case. Please let us know your preferences and availability for trial dates from September 2021 through the end of the year. If you could please provide details for any conflicts, that would be helpful. Thank you, EFTA00096051