DOJ-OGR-00005269.pdf

Case 1:20-cr-00330-PAE Document 362 Filed 10/20/21 Page 1 of 4 REPORTERS COMMITTEE FOR FREEDOM OF THE PRESS October 20, 2021 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, With the government's consent, the defendant has requested to file the parties' joint proposed juror questionnaire and joint proposed voir dire under seal. Letter of U.S. Att'y, October 12, 2021 (Dkt. No. 339) ("Letter"). The Reporters Committee for Freedom of the Press and the 17 undersigned news media organizations respectfully urge the Court to deny the defendant's request. Globe Newspaper Co. v. Superior Ct. for Norfolk Cty., 457 U.S. 596, 609 n.25 (1982) (stating that "representatives of the press and general public must be given an opportunity to be heard on the question of their exclusion" (cleaned up)).1 Both the common law and the First Amendment afford the public a qualified right of access to criminal proceedings. Indeed, the Supreme Court has long recognized that public access to criminal proceedings assures both the fairness and legitimacy of the criminal justice system. Id. at 606 ("Public scrutiny of a criminal trial enhances the quality and safeguards the integrity of the factfinding process, 1 The defendant also has requested that the Court order "individual sequestered juror voir dire and limited counsel-conducted voir dire." ECF No. 341. The government opposes both requests. ECF No. 355. To the extent that the defendant seeks to limit press and public access to any aspect of voir dire in this case, the same constitutional and common law presumptions of public access discussed herein apply. DOJ-OGR-00005269