Case 1:20-cr-00330-PAE Document590 _ Filed 02/01/22 Page1of9
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Christian R. Everdell
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February 1, 2022
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 82 20 Cr. 330 (AJN)
Dear Judge Nathan:
We write in response to the Court’s order, dated January 26, 2022, requiring the defense to
file a letter on the public docket justifying our request to seal Ms. Maxwell’s Motion for a New
Trial and accompanying exhibits (collectively, the “Motion’’) under the three-part test in Lugosch
v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Dkt. 585.
Introduction
The Motion urges the Court to right a grievous wrong that deprived Ms. Maxwell of a
fundamental constitutional right — her right to be tried by a fair and impartial jury. Juror 50’s
responses to the jury questionnaire and questions posed to him during in-person voir dire
corrupted the voir dire process and violated Ms. Maxwell’s right to a fair trial. As set forth in the
Motion, the defense believes that the existing record is clear and more than sufficient for the Court
to grant Ms. Maxwell a new trial without the need for further factual development. Should the
Court agree with the defense, the Motion could be unsealed and publicly docketed at the same
time the Court issues its ruling with no additional delay.
2087306.1
DOJ-OGR-00008852