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U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
USDC SDNY New York, New York 10007
DOCUMENT | ew L£0rk, ew Iori
ELECTRONICALLY FILED
DOC #;
November 4, 2021
DATE FILED: 11/5/21 °
BY ECF ;
— For the reasons stated in the Government's
The Honorable Alison J. Nathan letter, the motion for reconsideration, Dkt.
United States District Court No. 407, is DENIED. SO ORDERED.
Southern District of New York
United States Courthouse Ate () ia
40 Foley Square 11/5/21
New York, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter in response to the Court’s Order dated
November 3, 2021 (the “Order,” Dkt. No. 413), directing the Government to respond to the
defendant’s November 3, 2021 motion for reconsideration regarding the disclosure of juror names
(Dkt. No. 407). The Government respectfully submits that the defendant’s motion for
reconsideration should be denied.
The standard for granting reconsideration “‘is strict, and reconsideration will generally be
denied unless the moving party can point to controlling decisions or data that the court
overlooked—amatters, in other words, that might reasonably be expected to alter the conclusion
reached by the court.’” Boyd v. United States, No. 12 Civ. 474 (JSR), 2015 WL 1345809, at *2
(S.D.N.Y. Mar. 20, 2015) (quoting Shrader v. CSX Transp., Inc., 70 F.3d 255, 257 (2d Cir. 1995));
see also 8.D.N.Y. Local Criminal Rule 49.1(d). “The major grounds justifying reconsideration
are an intervening change of controlling law, the availability of new evidence, or the need to correct
a clear error or prevent manifest injustice.” United States v. Sanchez, No. 08 Cr. 789 (RJS), 2020
WL 4742915, at *1 (S.D.N.Y. July 6, 2020) (citation and internal quotation marks omitted).
DOJ-OGR-00006175