DOJ-OGR-00008962.pdf

--- Page 1 --- The extracted text from the document image is: **Header:** * Case 1:20-cr-00330-AJN * Document 602 * Filed 02/16/22 * Page 1 of 1 **Law Offices of Bobbi C. Sternheim** * Contact Information: + Phone: 212-243-1100 + Fax: 888-587-4737 + Email: bcsternheim@mac.com + Address: 225 Broadway, Suite 715, New York, NY 10007 **Date:** February 16, 2022 **To:** 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, BOBBI C. STERNHEIM Attachments (to be kept under seal pending the Court's decision regarding redactions) cc: Counsel of Record