Case 1:20-cr-00330-AJN Document 602 Filed 02/16/22 Page 1 of 1
LAW OFFICES OF BOBBI C. STERNHEIA\
212-243-1100 « Main 225 Broadway, Suite 715
917-912-9698 « Cell New York, NY 10007
888-587-4737 * Fax
[email protected]
February 16, 2022
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:
The annexed documents pertaining to Ghislaine Maxwell’s motion for a new trial, previously
submitted under seal, contain proposed redactions in conformance with the Court’s Order (Dkt. 596).
The proposed redactions are intended to ensure the integrity of any fact-gathering process to
uncover the truth surrounding Juror 50 ‘s conduct during the voir dire process. Any inquiry will be
focused primarily on the testimony of Juror 50. The proposed redactions reduce the risk that his testimony
will be tailored based on a preview of information central to the inquiry or otherwise tainted by outside
information and influence. The proposed redactions pertain to the following information:
= Juror 50’s exact responses to the questions on his jury questionnaire, which is being kept
temporarily under seal. See Dkt. 596 at 5, fn 1.
= Data about the responses of other jurors and potential jurors to the jury questionnaire.
= Details of investigative steps the defense has taken and evidence uncovered thus far.
= The defense’s view of the underlying facts.
= The scope of the defense’s requested discovery in advance of the hearing.
Very truly yours,
/s/
BOBBI C. STERNHEIM
Attachments (to be kept under seal pending the Court’s decision regarding redactions)
cc: Counsel of Record
DOJ-OGR- 00008962