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
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Document 598
AI Analysis
Summary: The Government agrees with the New York Times Company that the questionnaires for the twelve seated jurors in the Ghislaine Maxwell case should be made public, with limited redactions to protect juror privacy. The Government proposes redactions to only one juror questionnaire to protect sensitive personal information. The letter is a response to the Court's order regarding the New York Times Company's motion to unseal the juror questionnaires.
Significance: This document is significant because it reveals the Government's position on unsealing juror questionnaires in a high-profile case, and it provides insight into the balance between transparency and juror privacy.
Key Topics:
Unsealing juror questionnaires
Redactions for juror privacy
Access to jury selection process
Key People:
- Ghislaine Maxwell - Defendant in the case
- Alison J. Nathan - United States District Judge
- Damian Williams - United States Attorney
- Maurene Comey - Assistant United States Attorney
- Alison Moe - Assistant United States Attorney
- Lara Pomerantz - Assistant United States Attorney
- Andrew Rohrbach - Assistant United States Attorney
Full Text
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
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Case 1:20-cr-00330-PAE Document 598 Filed 02/11/22 Page 2 of 2
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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
Individual Pages
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Case 1:20-cr-00330-PAE Document 598 Filed 02/11/22 Page 2 of 2
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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