Case 1:20-cr-00330-PAE Document 649 _ Filed 03/15/22 Page1of12
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]
March 15, 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, S82 20 Cr. 330 (AJN)
Dear Judge Nathan:
We respectfully submit this letter following the hearing on March 8, 2022 (the
“Hearing”) in further support of Ghislaine Maxwell’s Motion for a New Trial (“Motion”).
The Court has now heard from Juror 50 in his own words. If there is one thing we
learned from Juror 50 at the Hearing, it is this: he should never have been a member of this jury.
Juror 50 conceded that he gave false responses to not one, but three critical questions on the juror
questionnaire, all of which, had he answered them truthfully, would have revealed his prior
sexual abuse. The abuse Juror 50 described at the Hearing, which he should have disclosed on
the questionnaire and during voir dire, was remarkably similar to the abuse described by the
government’s four key victim witnesses and would, by itself, have formed the basis for a
challenge for cause. Moreover, his answers to the Court’s questions, which he gave after careful
preparation by his attorney and under the protection of government-granted immunity, alternated
between inconsistent, implausible, and contradictory, and at all times lacked credibility.
Juror 50’s explanation that he “flew through” the questionnaire does not hold water, and
his repeated after-the-fact assurances that the sexual abuse he suffered as a child did not affect
his ability to be a fair and impartial juror were self-serving and simply not believable. Like
anyone in his position, Juror 50 does not want to be responsible for the retrial of Ghislaine
DOJ-OGR-00010307