Document 727

Case 1:20-cr-00330-PAE Document 727 Filed 07/14/22 Page 1 of 2 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 November 14, 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: The parties respectfully submit this joint letter in response to the Court's email earlier today regarding prospective jurors that the Court proposes to strike from the list of jurors proceeding to voir dire. I. The Parties' Positions Regarding the Court's List The parties have conferred about the Court's proposed list of strikes. The government has no objection to the Court's proposal to strike all jurors on the list. The defense largely agrees with the Court's proposal, but requests that a limited number of jurors on the list proceed to voir dire so that the Court can inquire further about the nature of any travel or hardship conflict that these jurors have identified. More specifically, the defense agrees that the following jurors should be excused from voir dire: 23, 114, 215, 257, 338, 420, 422, 542, 561 2051282.1 DOJ-OGR-00011384 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 727 Filed 07/14/22 Page 2 of 2 The Honorable Alison J. Nathan November 14, 2021 Page 2 The defense proposes that the following jurors should proceed to voir dire so that the Court can inquire further about the travel or hardship reasons that may prevent them from serving as jurors on this case: 196, 290, 419, 562 II. Modified Defense Strikes The defense also writes to advise the Court of a small number of prospective jurors that the defense intended to strike, but inadvertently indicated should proceed to voir dire. The defense believes that the following jurors should be stricken and should not proceed to voir dire: 92, 226, 404 We have conferred with the government about these proposed strikes. The government maintains its position that these jurors should proceed to voir dire. Sincerely, /s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600 cc: All Counsel of Record (By ECF) 2051282.1 DOJ-OGR-00011385