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Document 373

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Case 1:20-cr-00330-AJN Document 373 Filed 10/26/21 Page 1 of 2 LAW OFFICES OF BOBBI C. STERNHEIM 212-243-1100 · Main 225 Broadway, Suite 715 917-912-9698 · Cell New York, NY 10007 888-587-4737 · Fax bcsternheim@mac.com October 26, 2021 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: Counsel for Ghislaine Maxwell respectfully submit this letter in response to the Court's Order dated October 22, 2021, regarding the Court's draft preliminary remarks for prospective jurors. (Dkt. 366). The defense has no objection to the proposed remarks. However, the defense does object to the government's position that the parties should not receive the names of the prospective jurors until the first day of oral voir dire on November 16, 2021. (Dkt. 371). The Court has already determined that the names of the prospective jurors will be given to the parties with the juror questionnaires. The second page of the Court's draft jury questionnaire is a blank page that will be filled in with the "juror information sheet from the jury department." (Dkt. 365). It is the defense's understanding that the juror information sheet includes the name of the prospective juror. If the government had wanted to delay the disclosure of the names of the prospective jurors, they could have made a request to the Court when the parties submitted their joint proposed juror questionnaire. The government did not do so. Accordingly, the Court should deny this request. Very truly yours, /s/ BOBBI C. STERNHEIM cc: Government Counsel DOJ-OGR-00005383 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 373 Filed 10/26/21 Page 2 of 2 2 DOJ-OGR-00005384

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Case 1:20-cr-00330-AJN Document 373 Filed 10/26/21 Page 1 of 2 LAW OFFICES OF BOBBI C. STERNHEIM 212-243-1100 · Main 225 Broadway, Suite 715 917-912-9698 · Cell New York, NY 10007 888-587-4737 · Fax bcsternheim@mac.com October 26, 2021 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: Counsel for Ghislaine Maxwell respectfully submit this letter in response to the Court's Order dated October 22, 2021, regarding the Court's draft preliminary remarks for prospective jurors. (Dkt. 366). The defense has no objection to the proposed remarks. However, the defense does object to the government's position that the parties should not receive the names of the prospective jurors until the first day of oral voir dire on November 16, 2021. (Dkt. 371). The Court has already determined that the names of the prospective jurors will be given to the parties with the juror questionnaires. The second page of the Court's draft jury questionnaire is a blank page that will be filled in with the "juror information sheet from the jury department." (Dkt. 365). It is the defense's understanding that the juror information sheet includes the name of the prospective juror. If the government had wanted to delay the disclosure of the names of the prospective jurors, they could have made a request to the Court when the parties submitted their joint proposed juror questionnaire. The government did not do so. Accordingly, the Court should deny this request. Very truly yours, /s/ BOBBI C. STERNHEIM cc: Government Counsel DOJ-OGR-00005383
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Case 1:20-cr-00330-AJN Document 373 Filed 10/26/21 Page 2 of 2 2 DOJ-OGR-00005384