212-243-1100 • Main 917-912-9698 • Cell 888-587-4737 • Fax¶
February 21, 2022¶
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)
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Dear Judge Nathan:¶
225 Broadway, Suite 715 New York, NY 10007 bcsternheim@mac.com¶
The annexed documents, previously submitted under seal, contain proposed redactions in conformance with the Court’s Orders (Dkt. 596, 605).1¶
The proposed redactions are intended to ensure the integrity of the fact-finding process to uncover the truth surrounding Juror 50’s conduct during the voir dire process, to ensure juror anonymity and privacy, and to preserve specific factual information developed by the defense that has not been publicly reported and that the defense proposes to inquire about at any forthcoming hearing.¶
In an abundance of caution, we have proposed redactions to information and data about the responses of other jurors (selected and prospective) to the jury questionnaire because the questionnaires and sealed portions of the voir dire transcript are not part of the public record. The public disclosure of juror information, even if provided anonymously, risks compromising the integrity of the jury selection process and the willingness of potential jurors to disclose personal information.¶
Very truly yours,¶
/s/¶
BOBBI C. STERNHEIM¶
Attachments cc: Counsel of Record¶
{sup}' The documents - Ghislaine Maxwell’s Motion for a New Trial, the Government’s Opposition, and Ms. Maxwell’s Reply - will remain under seal pending the Court’s decision regarding the proposed redactions.¶