Case 1:20-cr-00330-AJN Document 356 Filed 10/18/21 Page 1 of 1
LAW OFFICES OF BOBBI C. STERNHEIA\
212-243-1100 * Main 225 Broadway, Suite 715
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[email protected]
October 18, 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:
There is nothing surprising about the government’s opposition to limited attorney-
conducted voir dire and individual sequestered voir dire. (Dkt. 355.) The government’s response
is standard SDNY operating procedure: “We don’t do that here.” Rarely is there an AUSA who
has ever conducted voir dire, so it is easy to just say “no.” In this case, counsel are better
positioned to address particular areas of case-related bias than is the Court, and requesting a mere
minute per juror is far from onerous.
The proposed questionnaire seeks highly sensitive and personal information regarding
each juror. Simply asking jurors to raise their hand in response to an invitation to speak privately
on a personal topic is revealing and invasive. One would hope that the government would be
sensitive to that fact and would want to ensure that a fair and impartial jury will be seated in this
high-profile case. With each passing day, the amount of public exposure this case receives erodes
that possibility. Below are today’s Google search results:
= Ghislaine Maxwell: “about 4,740,000 (about 0.89 seconds)”
" Jeffrey Epstein: “about 26,200,000 results (0.86 seconds)”
The Court has the power and the obligation to ensure that jury selection eliminates jurors
who are biased and/or motivated to serve for reasons beyond being fair and impartial.
This is an extraordinary case involving sensitive issues. We urge the Court to exercise its
supervisory powers and discretion and grant the defense request for individual sequestered voir
dire and very limited counsel-conducted voir dire.
Very truly yours,
/s/
BOBBI C. STERNHEIM
cc: All Counsel
DOJ-OGR-00005255