Document 419

Case 1:20-cr-00330-PAE Document 419 Filed 11/08/21 Page 1 of 2 LAW OFFICES OF BOBBI C. STERNHEIM 212-243-1100 • Main 917-912-9698 • Cell 888-587-4737 • Fax 225 Broadway, Suite 715 New York, NY 10007 bcsternheim@mac.com November 8, 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: In response to the Court's order (Dkt. 404), the defense proposes the following suggestions in bold to the preliminary remarks to be recorded and played before each voir dire session: Page 3, Lines 11-12: You can't assume that she is guilty or more likely to be guilty just because she's been charged in an indictment and alleged to have committed the crimes charged. with committing these crimes. Page 4, Lines 12-13: Another instruction, from today until you are excused from jury service, you can't look up or google or do any kind of research or search in any manner about anything related to the case or anyone involved in the case. Page 4, Following Line 23: The attorneys and their assistants have been instructed by me not to speak to you or otherwise engage with you. They are not being rude or indifferent. They are merely following my instructions. DOJ-OGR-00006195 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 419 Filed 11/08/21 Page 2 of 2 LAW OFFICES OF BOBBI C. STERNHEIM Page 5, Line 7: any communications about the case through any means or using any recording or photography features on your phone) Very truly yours, /s/ BOBBI C. STERNHEIM cc: All counsel of record 2 DOJ-OGR-00006196