Case 1:20-cr-00330-PAE Document 419 Filed 11/08/21 Pagelof2
LAW OFFICES OF BOBBI C. STERNHEIA\
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November 8, 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:
In response to the Court’s order (Dkt. 404), the defense proposes the following
suggestions in bold to the preliminary remarks to be recorded and played before each voir dire
session:
Page 3, Lines 11-12:
You can’t assume that she is guilty or more likely to be guilty just because she’s been
charged in an indictment and alleged to have committed the crimes charged. with
tine # mes.
Page 4, Lines 12-13:
Another instruction, from today until you are excused from jury service, you can’t look
up or google or do any kind of research or search in any manner about anything related
to the case or anyone involved in the case.
Page 4, Following Line 23:
The attorneys and their assistants have been instructed by me not to speak to you or
otherwise engage with you. They are not being rude or indifferent. They are merely
following my instructions.
DOJ-OGR-00006195