Case 1:20-cr-00330-PAE Document 407 _ Filed 11/03/21 Pagelof7
LAW OFFICES OF BOBBI C. STERNHEIA\
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November 3, 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:
Counsel for Ghislaine Maxwell renew our request that the Court release the names of
potential jurors, for attorneys’ eyes only, as soon as the written questionnaires are distributed.
Based on the Court’s statement during the October 21 teleconference, it was counsel’s
understanding that juror names would be provided to counsel on the Juror Sheet to be inserted in
the questionnaire. In responding to the Court’s order regarding approval of the video to be played
to prospective jurors, the government importuned the Court to deny counsel the opportunity to
properly vet jurors at this critical state of the proceeding. Not knowing the names of the
potential jurors will prevent the parties from conducting necessary background research on the
jurors in advance of voir dire so that they may evaluate potential challenges and strikes. Due to
the large number of potential jurors (600), waiting until voir dire to release the names of the
jurors will make it virtually impossible for the parties to conduct any meaningful research to
uncover issues that may require follow-up questions, lead to additional cause challenges, or
enable the parties to exercise their peremptory challenges in an informed manner.
Recently, in Sines, et al. v. Kessler, et al., 17-CV-72 (KNM) (W.D. Va.), the civil case
brought against the organizers of the Unite the Right rally in Charlottesville, Virginia, the United
DOJ-OGR-00006049