Case 1:20-cr-00330-PAE Document595- Filed 02/08/22 Page1of1i1
LAW OFFICES OF BOBBI C. STERNHEIA\
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February 8, 2022
Honorable Alison J. Nathan
United States District Court
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, dated January 26, 2022 (Dkt. 585), and for the reasons
stated in the defense letter, dated February 1 (Dkt. 590) (annexed hereto for convenience),
Ghislaine Maxwell requests that the government’s response and accompanying exhibits in
opposition to Ms. Maxwell’s Motion for a New Trial (“Motion”) (dated February 2, 2022)
remain under seal until the Court decides the pending Motion or until the conclusion of any
hearing held on the Motion.
With the constitutional right to a fair trial at stake, it is of paramount importance for
the Court to ensure the integrity of any fact-gathering process that may take place so that the
inquiry is safeguarded and can uncover the truth of what happened. Public filing of Ms.
Maxwell’s Motion, the government’s response, and Ms. Maxwell’s reply (to be filed on
February 9) places those principles at risk. Giving Juror 50 a preview of information he does
not have and should not have at this juncture would permit him to craft testimony, destroy
critical evidence, and explain away facts to protect himself while further jeopardizing the
integrity of this case. The absence of this temporary safeguard will contribute to further
obstruction of the truth-seeking process, compromising any factual inquiry ordered by the
DOJ-OGR- 00008898