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_ Case 1:20-cr-00330-PAE Document 355 Filed 10/18/21 Page1of5
aN U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
October 18, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter pursuant to the Court’s Order dated
October 14, 2021 (Dkt. No. 343) directing the Government to respond to the defendant’s motion
for an order granting limited counsel-conducted voir dire and individual sequestered voir dire (Dkt.
No. 341).
1. Attorney Voir Dire Is Not Warranted
None of the defendant’s arguments warrant departing from the well-settled practice in this
District of Court-led voir dire. The Court is well-equipped to thoroughly question prospective
jurors and to appropriately filter questions prepared by the parties.
It is well established that “[a] district court is ‘accorded ample discretion in determining
how best to conduct .. . voir dire.’” United States v. Lawes, 292 F.3d 123, 128 (2d Cir. 2002)
(quoting Rosales-Lopez v. United States, 451 U.S. 182, 189 (1981)); accord United States v.
Quinones, 511 F.3d 289, 299 (2d Cir. 2007). As a general matter, “[v]Joir dire is necessarily a
matter in which the trial court has extremely broad discretion,” and “federal trial judges are not
required to ask every question that counsel—even all counsel—believes is appropriate.” Lawes,
DOJ-OGR-00005250