Page 1 of 5
Céest: 2QOrOCKRBOAEN DmmunentSB Afieet1D21R92 Patege afar 5
| USDC SDNY
DOCUMENT
DOC #;
ELECTRONICALLY FILED ||
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
DATE FILED: 12/19/21
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, 82 20 Cr. 330 (AJN) AN ( | | y
Dear Judge Nathan:
December 19, 2021
The parties previously indicated to the Court that they did not intend to
make the visuals of the closing argument presentations public. The Court
accordingly ordered the parties to confer on a proposal so as to ensure
public access. For the reasons provided by the parties, the Court adopts
the parties’ proposal. Versions of the closing argument visual
presentations with narrowly tailored redactions (e.g., redactions to
protect the anonymity of witnesses the Court has permitted to testify
under pseudonyms) shall be made available to the public within two
hours of the completion of closing arguments. SO ORDERED.
12/19/21
The parties respectfully submit this letter regarding the logistics for public access for
closing arguments. The parties propose that they will release a public version of their slides (to
the extent they do not contain sealed materials) following the conclusion of the trial day on the
same basis that they have been releasing public exhibits during trial. This proposal appropriately
balances the public interest in access to closing arguments with the Court and the parties’ interests
in avoiding delay and effective advocacy on behalf of their clients, as well as the interests of
victims and third parties protected by the Court’s sealing orders.!
' Closing argument demonstratives are not part of the official trial record. The approach jointly
proposed by the parties is consistent with trials conducted without electronics, where the public
would not be in a position to see white boards or easel displays positioned facing the jury box.
1
DOJ-OGR-00008448