Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 1 of 10 EXHIBIT 2 DOJ-OGR-00009098
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Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 1 of 10 EXHIBIT 2 DOJ-OGR-00009098
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Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 2 of 10 1 LBG8MAXVD1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -------------------------------x UNITED STATES OF AMERICA, v. 20-cr-330 (AJN) GHISLAINE MAXWELL, Defendant. -------------------------------x Voir Dire New York, N.Y. November 16, 2021 8:45 a.m. Before: HON. ALISON J. NATHAN, District Judge APPEARANCES DAMIAN WILLIAMS United States Attorney for the Southern District of New York BY: MAURENE COMEY ALISON MOE LARA POMERANTZ ANDREW ROHRBACH Assistant United States Attorneys HADDON MORGAN AND FOREMAN Attorneys for Defendant BY: JEFFREY S. PAGLIUCA CHRISTIAN R. EVERDELL LAURA A. MENNINGER -and- BOBBI C. STERNHEIM Attorney for Defendant -and- RENATO STABILE Attorney for Defendant Also Present: SUNNY DRESCHER, Paralegal, U.S. Attorney's Office CAMILLE DELGADO, Paralegal, Haddon Morgan and Foreman SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
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Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 3 of 10 128
LBG8MAXVD1
1 MR. PAGLIUCA: No, your Honor. Thank you.
2 THE COURT: Thank you.
3 Juror No. 49, thank you. My law clerk is going to
4 give you instructions about the next step. Thank you for your
5 time.
6 (Juror exits courtroom)
7 THE COURT: Juror No. 50.
8 (Juror present)
9 THE COURT: Good afternoon, Juror No. 50. I am Judge
10 Nathan. It's nice to see you in person, and thank you for your
11 time.
12 I am going to ask you some follow-up questions related
13 to some of your responses that you provided and some additional
14 questions.
15 First, as I instructed you earlier, the defendant in
16 this case, Ms. Maxwell, is presumed innocent of all charges
17 unless and until the government proves her guilt beyond a
18 reasonable doubt. Are you able to follow that instruction?
19 JUROR: Yes.
20 THE COURT: As I instructed you, until you are excused
21 from the case, you may not take in any kind of media about the
22 case, social media, TV, radio, online, print, anything, or
23 discuss the case with anyone. Would you have any difficulty
24 following that instruction?
25 JUROR: No.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00009100
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Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 4 of 10 129 LBG8MAXVD1
1 THE COURT: Since you took the questionnaire -- now is
2 the time to tell me -- have you read or researched or discussed
3 the case with anyone?
4 JUROR: I have not.
5 THE COURT: Schedule. The trial will start on
6 November 29. We estimate approximately six weeks. Can you sit
7 during that time?
8 JUROR: Yes.
9 THE COURT: I am going to ask you to pick up the
10 binder in front of you, please.
11 If you turn to Tab 2, there are three pages that lists
12 names of people who may be mentioned during the trial. I want
13 you to take your time, read all of those names. If there are
14 any that are familiar to you, please let me know what number.
15 JUROR: None.
16 THE COURT: Three pages.
17 JUROR: None.
18 THE COURT: Then the next tab is one page, and it
19 lists some addresses and entities that may be mentioned during
20 trial. Here, the question is not whether you have heard of any
21 of them, but do you have any specific familiarity?
22 JUROR: No.
23 THE COURT: Then the last tab. As the instructions
24 say, don't say it out loud, but just yes or no. Other than
25 having heard of it, do you have any specific familiarity?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00009101
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Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 5 of 10 130 LBG8MAXVD1
1 JUROR: No, I do not.
2 THE COURT: You can put that aside.
3 You have indicated in your questionnaire that before
4 the questionnaire you had heard about Ms. Maxwell. Do you
5 recall where you heard about her?
6 JUROR: I heard when Jeffrey Epstein had died that he
7 had had a girlfriend, just from a news article, a news
8 broadcast on CNN.
9 THE COURT: Other than what you just described, do you
10 remember hearing anything else about Ms. Maxwell?
11 JUROR: Nothing.
12 THE COURT: The question is -- it's an important
13 question -- can you put aside anything that you have read or
14 heard about Ms. Maxwell and decide the case based on the facts
15 and evidence, or lack of evidence, here presented in court?
16 JUROR: Absolutely.
17 THE COURT: And follow my instructions as to the law?
18 JUROR: Yes.
19 THE COURT: In your questionnaire, you indicated
20 before the questionnaire you had heard about Mr. Epstein. What
21 you described, you said CNN. Other than what you have
22 described, do you recall anything that you heard about Mr.
23 Epstein?
24 JUROR: Not really. I don't really have cable, so
25 it's very rare that I even see anything.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
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Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 6 of 10 131 LBG8MAXVD1
1 THE COURT: Based on what you did here or read previously, same question, can you put it aside, decide the case based on the facts and evidence, or lack of evidence, here presented in court?
2 JUROR: Yes.
3 THE COURT: Any doubt about that?
4 JUROR: No doubt.
5 THE COURT: Let me ask you, do you have any reason to think you might have any bias either for or against law enforcement of any kind?
6 JUROR: No.
7 THE COURT: Any reason to think you have any bias for or against criminal defense lawyers?
8 JUROR: No.
9 THE COURT: Do you have any opinion about the criminal justice system, generally, or the federal criminal justice system that might make it difficult for you to be fair and impartial here?
10 JUROR: No.
11 THE COURT: Do you have any opinion about people who are wealthy or who have luxurious lifestyles that might make it difficult for you to be fair and impartial here?
12 JUROR: No.
13 THE COURT: Counsel, anything further before background questions?
SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
DOJ-OGR-00009103
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Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 7 of 10 132 LBG8MAXVD1
1 MS. POMERANTZ: No.
2 MS. STERNHEIM: No.
3 THE COURT: Juror No. 50, how old are you?
4 JUROR: I am 35.
5 THE COURT: What county do you live in?
6 JUROR: I live in Manhattan.
7 THE COURT: How long have you lived here?
8 JUROR: Ten years.
9 THE COURT: How far did you go in school?
10 JUROR: I finished my bachelor's degree.
11 THE COURT: What did you study?
12 JUROR: Finance.
13 THE COURT: Are you working now?
14 JUROR: Yes.
15 THE COURT: What kind of work?
16 JUROR: I am an executive assistant in finance.
17 THE COURT: And you work at a private company of some kind?
18 kind?
19 JUROR: Yes.
20 THE COURT: How long have you been in that position?
21 JUROR: With this company, almost four years now.
22 THE COURT: Same position with another company prior to that?
23 to that?
24 JUROR: Yes. Ever since I graduated college in 2008.
25 THE COURT: Do you live with anybody?
SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
DOJ-OGR-00009104
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Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 8 of 10 133 LBG8MAXVD1 1 JUROR: I live alone. 2 THE COURT: Do you typically read any newspapers or 3 magazines, either in print or online? 4 JUROR: No, I do not. 5 THE COURT: Do you frequently visit any particular 6 websites? 7 JUROR: No. 8 THE COURT: Ever comment or post on websites? 9 JUROR: No. 10 THE COURT: Do you use social media? 11 JUROR: I do, but I actually just deleted them because 12 I just got out of a relationship and I didn't want to see 13 anything regarding them. So I am fully off of it right now. 14 THE COURT: What did you use, Facebook, Twitter? 15 JUROR: I used Facebook and Instagram. 16 THE COURT: When you had those, what kind of stuff 17 would you post? Would you post about news of the day or 18 politics or personal stuff? 19 JUROR: Personal stuff, like selfies. 20 THE COURT: How long ago did you delete your accounts? 21 JUROR: It was actually last week. 22 THE COURT: Do you watch television? 23 JUROR: I have Netflix, so I watch Netflix. 24 THE COURT: What kind of shows? 25 JUROR: Comedies, funny things. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009105
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Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 9 of 10 134 LBG8MAXVD1
1 THE COURT: Do you listen to the radio?
2 JUROR: I do not. I do listen to music, though.
3 THE COURT: What about podcasts?
4 JUROR: I do not.
5 THE COURT: Hobbies or things you do for fun?
6 JUROR: I love to travel and hang out with friends.
7 THE COURT: Have you ever followed a criminal case either on the news or podcasts or the like?
8 JUROR: I have not.
9 THE COURT: Any clubs or organizations to which you contribute time or money?
10 JUROR: I do not contribute to anything right now.
11 THE COURT: You have in the past?
12 JUROR: In college.
13 THE COURT: In these questions, I have tried to, of course, get a sense of whether you can be fair to both sides in this case. Any doubt about your ability to do that?
14 JUROR: No.
15 THE COURT: Other than what I have asked you, do you have any reason to think that you can't be fair and impartial here?
16 JUROR: I do not.
17 THE COURT: Counsel, any questions?
18 MS. POMERANTZ: No. Thank you.
19 MS. STERNHEIM: No. Thank you.
20 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
21 DOJ-OGR-00009106
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Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 10 of 10 135 LBG8MAXVD1 1 THE COURT: Juror No. 50, thank you so much. My law clerk is going to give you instructions about the next step, and I thank you for your time. 4 (Juror exits courtroom) 5 (Continued on next page) 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009107
Individual Pages
Page 1 - DOJ-OGR-00009098
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Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 2 of 10 1 LBG8MAXVD1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -------------------------------x UNITED STATES OF AMERICA, v. 20-cr-330 (AJN) GHISLAINE MAXWELL, Defendant. -------------------------------x Voir Dire New York, N.Y. November 16, 2021 8:45 a.m. Before: HON. ALISON J. NATHAN, District Judge APPEARANCES DAMIAN WILLIAMS United States Attorney for the Southern District of New York BY: MAURENE COMEY ALISON MOE LARA POMERANTZ ANDREW ROHRBACH Assistant United States Attorneys HADDON MORGAN AND FOREMAN Attorneys for Defendant BY: JEFFREY S. PAGLIUCA CHRISTIAN R. EVERDELL LAURA A. MENNINGER -and- BOBBI C. STERNHEIM Attorney for Defendant -and- RENATO STABILE Attorney for Defendant Also Present: SUNNY DRESCHER, Paralegal, U.S. Attorney's Office CAMILLE DELGADO, Paralegal, Haddon Morgan and Foreman SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
Page 3 - DOJ-OGR-00009100
Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 3 of 10 128
LBG8MAXVD1
1 MR. PAGLIUCA: No, your Honor. Thank you.
2 THE COURT: Thank you.
3 Juror No. 49, thank you. My law clerk is going to
4 give you instructions about the next step. Thank you for your
5 time.
6 (Juror exits courtroom)
7 THE COURT: Juror No. 50.
8 (Juror present)
9 THE COURT: Good afternoon, Juror No. 50. I am Judge
10 Nathan. It's nice to see you in person, and thank you for your
11 time.
12 I am going to ask you some follow-up questions related
13 to some of your responses that you provided and some additional
14 questions.
15 First, as I instructed you earlier, the defendant in
16 this case, Ms. Maxwell, is presumed innocent of all charges
17 unless and until the government proves her guilt beyond a
18 reasonable doubt. Are you able to follow that instruction?
19 JUROR: Yes.
20 THE COURT: As I instructed you, until you are excused
21 from the case, you may not take in any kind of media about the
22 case, social media, TV, radio, online, print, anything, or
23 discuss the case with anyone. Would you have any difficulty
24 following that instruction?
25 JUROR: No.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00009100
Page 4 - DOJ-OGR-00009101
Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 4 of 10 129 LBG8MAXVD1
1 THE COURT: Since you took the questionnaire -- now is
2 the time to tell me -- have you read or researched or discussed
3 the case with anyone?
4 JUROR: I have not.
5 THE COURT: Schedule. The trial will start on
6 November 29. We estimate approximately six weeks. Can you sit
7 during that time?
8 JUROR: Yes.
9 THE COURT: I am going to ask you to pick up the
10 binder in front of you, please.
11 If you turn to Tab 2, there are three pages that lists
12 names of people who may be mentioned during the trial. I want
13 you to take your time, read all of those names. If there are
14 any that are familiar to you, please let me know what number.
15 JUROR: None.
16 THE COURT: Three pages.
17 JUROR: None.
18 THE COURT: Then the next tab is one page, and it
19 lists some addresses and entities that may be mentioned during
20 trial. Here, the question is not whether you have heard of any
21 of them, but do you have any specific familiarity?
22 JUROR: No.
23 THE COURT: Then the last tab. As the instructions
24 say, don't say it out loud, but just yes or no. Other than
25 having heard of it, do you have any specific familiarity?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00009101
Page 5 - DOJ-OGR-00009102
Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 5 of 10 130 LBG8MAXVD1
1 JUROR: No, I do not.
2 THE COURT: You can put that aside.
3 You have indicated in your questionnaire that before
4 the questionnaire you had heard about Ms. Maxwell. Do you
5 recall where you heard about her?
6 JUROR: I heard when Jeffrey Epstein had died that he
7 had had a girlfriend, just from a news article, a news
8 broadcast on CNN.
9 THE COURT: Other than what you just described, do you
10 remember hearing anything else about Ms. Maxwell?
11 JUROR: Nothing.
12 THE COURT: The question is -- it's an important
13 question -- can you put aside anything that you have read or
14 heard about Ms. Maxwell and decide the case based on the facts
15 and evidence, or lack of evidence, here presented in court?
16 JUROR: Absolutely.
17 THE COURT: And follow my instructions as to the law?
18 JUROR: Yes.
19 THE COURT: In your questionnaire, you indicated
20 before the questionnaire you had heard about Mr. Epstein. What
21 you described, you said CNN. Other than what you have
22 described, do you recall anything that you heard about Mr.
23 Epstein?
24 JUROR: Not really. I don't really have cable, so
25 it's very rare that I even see anything.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Page 6 - DOJ-OGR-00009103
Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 6 of 10 131 LBG8MAXVD1
1 THE COURT: Based on what you did here or read previously, same question, can you put it aside, decide the case based on the facts and evidence, or lack of evidence, here presented in court?
2 JUROR: Yes.
3 THE COURT: Any doubt about that?
4 JUROR: No doubt.
5 THE COURT: Let me ask you, do you have any reason to think you might have any bias either for or against law enforcement of any kind?
6 JUROR: No.
7 THE COURT: Any reason to think you have any bias for or against criminal defense lawyers?
8 JUROR: No.
9 THE COURT: Do you have any opinion about the criminal justice system, generally, or the federal criminal justice system that might make it difficult for you to be fair and impartial here?
10 JUROR: No.
11 THE COURT: Do you have any opinion about people who are wealthy or who have luxurious lifestyles that might make it difficult for you to be fair and impartial here?
12 JUROR: No.
13 THE COURT: Counsel, anything further before background questions?
SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
DOJ-OGR-00009103
Page 7 - DOJ-OGR-00009104
Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 7 of 10 132 LBG8MAXVD1
1 MS. POMERANTZ: No.
2 MS. STERNHEIM: No.
3 THE COURT: Juror No. 50, how old are you?
4 JUROR: I am 35.
5 THE COURT: What county do you live in?
6 JUROR: I live in Manhattan.
7 THE COURT: How long have you lived here?
8 JUROR: Ten years.
9 THE COURT: How far did you go in school?
10 JUROR: I finished my bachelor's degree.
11 THE COURT: What did you study?
12 JUROR: Finance.
13 THE COURT: Are you working now?
14 JUROR: Yes.
15 THE COURT: What kind of work?
16 JUROR: I am an executive assistant in finance.
17 THE COURT: And you work at a private company of some kind?
18 kind?
19 JUROR: Yes.
20 THE COURT: How long have you been in that position?
21 JUROR: With this company, almost four years now.
22 THE COURT: Same position with another company prior to that?
23 to that?
24 JUROR: Yes. Ever since I graduated college in 2008.
25 THE COURT: Do you live with anybody?
SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
DOJ-OGR-00009104
Page 8 - DOJ-OGR-00009105
Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 8 of 10 133 LBG8MAXVD1 1 JUROR: I live alone. 2 THE COURT: Do you typically read any newspapers or 3 magazines, either in print or online? 4 JUROR: No, I do not. 5 THE COURT: Do you frequently visit any particular 6 websites? 7 JUROR: No. 8 THE COURT: Ever comment or post on websites? 9 JUROR: No. 10 THE COURT: Do you use social media? 11 JUROR: I do, but I actually just deleted them because 12 I just got out of a relationship and I didn't want to see 13 anything regarding them. So I am fully off of it right now. 14 THE COURT: What did you use, Facebook, Twitter? 15 JUROR: I used Facebook and Instagram. 16 THE COURT: When you had those, what kind of stuff 17 would you post? Would you post about news of the day or 18 politics or personal stuff? 19 JUROR: Personal stuff, like selfies. 20 THE COURT: How long ago did you delete your accounts? 21 JUROR: It was actually last week. 22 THE COURT: Do you watch television? 23 JUROR: I have Netflix, so I watch Netflix. 24 THE COURT: What kind of shows? 25 JUROR: Comedies, funny things. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009105
Page 9 - DOJ-OGR-00009106
Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 9 of 10 134 LBG8MAXVD1
1 THE COURT: Do you listen to the radio?
2 JUROR: I do not. I do listen to music, though.
3 THE COURT: What about podcasts?
4 JUROR: I do not.
5 THE COURT: Hobbies or things you do for fun?
6 JUROR: I love to travel and hang out with friends.
7 THE COURT: Have you ever followed a criminal case either on the news or podcasts or the like?
8 JUROR: I have not.
9 THE COURT: Any clubs or organizations to which you contribute time or money?
10 JUROR: I do not contribute to anything right now.
11 THE COURT: You have in the past?
12 JUROR: In college.
13 THE COURT: In these questions, I have tried to, of course, get a sense of whether you can be fair to both sides in this case. Any doubt about your ability to do that?
14 JUROR: No.
15 THE COURT: Other than what I have asked you, do you have any reason to think that you can't be fair and impartial here?
16 JUROR: I do not.
17 THE COURT: Counsel, any questions?
18 MS. POMERANTZ: No. Thank you.
19 MS. STERNHEIM: No. Thank you.
20 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
21 DOJ-OGR-00009106
Page 10 - DOJ-OGR-00009107
Case 1:20-cr-00330-PAE Document 613-2 Filed 02/24/22 Page 10 of 10 135 LBG8MAXVD1 1 THE COURT: Juror No. 50, thank you so much. My law clerk is going to give you instructions about the next step, and I thank you for your time. 4 (Juror exits courtroom) 5 (Continued on next page) 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009107