DOJ-OGR-00008852.pdf

Case 1:20-cr-00330-PAE Document 590 Filed 02/01/22 Page 1 of 9 COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com February 1, 2022 BY ECF 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, S2 20 Cr. 330 (AJN) Dear Judge Nathan: We write in response to the Court's order, dated January 26, 2022, requiring the defense to file a letter on the public docket justifying our request to seal Ms. Maxwell's Motion for a New Trial and accompanying exhibits (collectively, the "Motion") under the three-part test in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Dkt. 585. Introduction The Motion urges the Court to right a grievous wrong that deprived Ms. Maxwell of a fundamental constitutional right - her right to be tried by a fair and impartial jury. Juror 50's responses to the jury questionnaire and questions posed to him during in-person voir dire corrupted the voir dire process and violated Ms. Maxwell's right to a fair trial. As set forth in the Motion, the defense believes that the existing record is clear and more than sufficient for the Court to grant Ms. Maxwell a new trial without the need for further factual development. Should the Court agree with the defense, the Motion could be unsealed and publicly docketed at the same time the Court issues its ruling with no additional delay. 2087306.1 DOJ-OGR-00008852