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Court filing · Nov. 8, 2021

An attorney letter to Judge Nathan on voir dire instructions, Nov. 2021

Defense counsel proposes edits to preliminary jury remarks before voir dire in the Ghislaine Maxwell criminal trial.Machine-written summary

Document EFTA 02834033

212-243-1100 • Main 225 Broadway, Suite 715 917-912-9698 • Cell New York, NY 10007 888.587-4737 • Fax bcstemheim@maccom

November 8, 2021

Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007

Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN)

Dear Judge Nathan:

In response to the Court’s order (Dkt. 404), the defense proposes the following suggestions in bold to the preliminary remarks to be recorded and played before each voir dire session:

Page 3. Lines 11-12:

You can’t assume that she is guilty or more likely to be guilty just because she’s been charged in an indictment and alleged to have committed the crimes charged. with eilimmitting-these-ecitnes:

Page 4. Lines 12-13:

Another instruction, from today until you are excused from jury service, you can’t look up or google or do any kind of research or search in any manner about anything related to the case or anyone involved in the case.

Page 4. Following Line 23:

The attorneys and their assistants have been instructed be me not to speak to you or othenvise engage with you. They are not being rude or indifferent. They are merely following my instructions.

Page 5. Line 7:

any communications about the case through any means or using any recording or photography features on your phone)

Very truly yours,

/s/

BOBBI C. STERNHEIM

cc: All counsel of record

An attorney letter to Judge Nathan on voir dire instructions, Nov. 2021

Court filings

Defense counsel proposes edits to preliminary jury remarks before voir dire in the Ghislaine Maxwell criminal trial.

Court Records: United States v. Maxwell (S.D.N.Y. 1:20-cr-00330) · Nov. 8, 2021

Document EFTA 02834033 212-243-1100 • Main 225 Broadway, Suite 715 917-912-9698 • Cell New York, NY 10007 888.587-4737 • Fax bcstemheim@maccom November 8, 2021 Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan: In response to the Court's order (Dkt. 404), the defense proposes the following suggestions in bold to the preliminary remarks to be recorded and played before each voir dire session: Page 3. Lines 11-12: You can't assume that she is guilty or mo…