Document 598

Case 1:20-cr-00330-PAE Document 598 Filed 02/11/22 Page 1 of 2 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 February 11, 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, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the Court's January 26, 2022 Order (Dkt. No. 585), which directed the Government to respond to the New York Times Company's motion to unseal the completed questionnaires for the twelve seated jurors in this case (Dkt. No. 583). The Government agrees with the New York Times Company that the questionnaires for the twelve seated jurors should be made public, with limited redactions to protect juror privacy. Under the circumstances presented here, where jury selection and the trial have been completed, releasing juror questionnaires is consistent with the strong presumption of access to the jury selection process, including juror questionnaires. See United States v. King, 140 F.3d 76, 80 (2d Cir. 1998); United States v. Avenatti, No. 19 Cr. 373 (PGG), 2021 WL 2809919, at *48 (S.D.N.Y. July 6, 2021). Regarding redactions, the Government proposes limited redactions to only one juror questionnaire and will submit the proposed redactions by email to Chambers. The redactions are limited to sensitive personal information, which the juror discussed at a sealed sidebar during voir dire. Aside from the limited redactions on one juror's questionnaire, the Government otherwise DOJ-OGR-00008921 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 598 Filed 02/11/22 Page 2 of 2 Page 2 does not seek redactions for the questionnaires completed by seated jurors. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (By ECF) DOJ-OGR-00008922