Page 1 of 4
__ Case 1:20-cr-00330-PAE Document 635 Filed 03/01/22 Page 1of4
aN 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
March 1, 2022
BY EMAIL
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:
In accordance with the Court’s February 24, 2022 Opinion and Order (Dkt. No. 620), the
Government respectfully submits this letter to propose questions for the public hearing at which
the Court will question Juror 50 under oath.
The Court has ordered that the scope of the hearing will be limited to three narrow
categories of inquiry: (1) whether Juror 50 provided false answers to Questions 25 and 48 on his
juror questionnaire, (2) the explanation for the answers he gave to those particular questions, and
(3) “how Juror 50 would have responded to follow-up questions if accurate answers had been
provided.” Feb. 24, 2022 Opinion and Order at 7. As an initial matter, the Government submits
that after placing Juror 50 under oath, the Court should give Juror 50 the following instruction
consistent with Rule 606(b): Iam going to ask you a series of focused questions today. I instruct
you not to tell me about the jury’s deliberations. I also instruct you not to tell me about your
thought processes as a deliberating juror. None of my questions will ask you about those subjects.
Following that instruction, the Government respectfully submits that the following
questions would be appropriate for each of the above three categories.
DOJ-OGR- 00009634