Case 1:20-cr-00330-PAE Document 636 Filed 03/01/22 Page1 of 22
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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, 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 February 24, 2022, permitting the parties
to submit proposed questions to the Court for the hearing related to Ms. Maxwell’s Motion for a
New Trial. Dkt. 610.
Renewed Request for Counsel to Conduct the Questioning of Juror 50
Ms. Maxwell reiterates her request that the Court allow counsel to conduct the questioning
of Juror 50 during the upcoming hearing. Attorney-conducted questioning enhances the
opportunity and ability to elicit bias on the part of the juror. See, e.g., Johnson & Haney, Felony
Voir Dire: An Exploratory Study of its Contents and Effect, 18 Law and Human Behavior 309
(1994). To smoke out the reasons why Juror 50 did not truthfully answer Questions 48 and 25 on
the jury questionnaire, he must be cross-examined. Defense counsel is in the best position to
conduct that cross-examination. This was the procedure that Judge Pauley followed in United
States v. Daugerdas, and there is no reason to follow a different procedure here. See Dkt. 616-1.
2100689.3
DOJ-OGR- 00009638