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Case 1:20-cr-00330-PAE Document598 _ Filed 02/11/22 Pagelof2
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
February 11, 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, 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 January 26, 2022
Order (Dkt. No. 585), which directed the Government to respond to the New York Times
Company’s motion to unseal the completed questionnaires for the twelve seated jurors in this case
(Dkt. No. 583). The Government agrees with the New York Times Company that the
questionnaires for the twelve seated jurors should be made public, with limited redactions to
protect juror privacy. Under the circumstances presented here, where jury selection and the trial
have been completed, releasing juror questionnaires is consistent with the strong presumption of
access to the jury selection process, including juror questionnaires. See United States v. King, 140
F.3d 76, 80 (2d Cir. 1998); United States v. Avenatti, No. 19 Cr. 373 (PGG), 2021 WL 2809919,
at *48 (S.D.N.Y. July 6, 2021).
Regarding redactions, the Government proposes limited redactions to only one juror
questionnaire and will submit the proposed redactions by email to Chambers. The redactions are
limited to sensitive personal information, which the juror discussed at a sealed sidebar during voir
dire. Aside from the limited redactions on one juror’s questionnaire, the Government otherwise
DOJ-OGR-00008921