Document 569

Case 1:20-cr-00330-PAE Document 569 Filed 01/05/22 Page 1 of 3 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 January 5, 2021 BY EMAIL 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 concerning an issue of pressing importance. It has come to the attention of the defense that one of the twelve jurors in this case (the "Juror") has been giving oral and videotaped interviews to various members of the press concerning the jury deliberations. These interviews have been publicly reported in several media outlets.1 Among other things, the Juror told reporters that he disclosed to the other members of the jury during deliberations that he was a victim of sexual abuse and further described his memory of those events. According to the Juror, his disclosure influenced the deliberations and convinced other members of the jury to convict Ms. Maxwell. [REDACTED] 1 See Lucia Osborne-Crowley, "'They were all believable': Maxwell juror says jury was convinced by accusers' accounts of a pattern of abuse," The Independent (Jan. 4, 2022); Laura Collins and Daniel Bates, "'Ghislaine was a predator as guilty as Epstein': Maxwell juror describes moment he 'locked eyes' with sex trafficker and reveals his own abuse ordeal," Daily Mail (Jan. 5, 2022), available at https://www.dailymail.co.uk/news/article-10370193/Ghislaine-Maxwell-juror-says-evidence-convinced-panel-predator.html; Luc Cohen, "Some Ghislaine Maxwell jurors initially doubted accusers, juror says," Reuters (Jan. 5, 2022). 2070301.1 DOJ-OGR-00008801 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 569 Filed 01/05/22 Page 2 of 3 The Honorable Alison J. Nathan January 5, 2021 Page 2 presents incontrovertible grounds for a new trial under Rule 33. Should the defense prevail on this motion—and we believe the law and facts are clearly on our side—it would render all other post-trial motions moot. Ms. Maxwell should not have to expend precious time and resources briefing other motions when this motion can and should be dispositive. Accordingly, the defense respectfully requests that the Court set a briefing schedule for this motion alone and defer setting a briefing schedule for any other post-trial motions. Sincerely, /s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor 2070301.1 DOJ-OGR-00008802 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 569 Filed 01/05/22 Page 3 of 3 The Honorable Alison J. Nathan January 5, 2021 Page 3 New York, New York 10022 (212) 957-7600 cc: All Counsel of Record (By Email) 2070301.1 DOJ-OGR-00008803