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Document 602
AI Analysis
Summary: The letter, written by defense attorney Bobbi C. Sternheim, requests that the court approve proposed redactions to documents related to Ghislaine Maxwell's motion for a new trial, citing concerns about protecting the integrity of the fact-gathering process surrounding Juror 50's conduct.
Significance: This document is potentially important because it reveals the defense's strategy and concerns regarding Juror 50's conduct and the potential impact on Ghislaine Maxwell's motion for a new trial.
Key Topics:
Ghislaine Maxwell's motion for a new trial
Proposed redactions to previously submitted documents
Juror 50's conduct during the voir dire process
Key People:
- Ghislaine Maxwell - Defendant
- Bobbi C. Sternheim - Defense Attorney
- Alison J. Nathan - United States District Judge
- Juror 50 - Juror whose conduct is under investigation
Full Text
Case 1:20-cr-00330-AJN Document 602 Filed 02/16/22 Page 1 of 1
LAW OFFICES OF BOBBI C. STERNHEIM
212-243-1100 · Main
917-912-9698 · Cell
888-587-4737 · Fax
225 Broadway, Suite 715
New York, NY 10007
bcsternheim@mac.com
February 16, 2022
Honorable Alison J. Nathan
United States District Judge
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 annexed documents pertaining to Ghislaine Maxwell's motion for a new trial, previously submitted under seal, contain proposed redactions in conformance with the Court's Order (Dkt. 596).
The proposed redactions are intended to ensure the integrity of any fact-gathering process to uncover the truth surrounding Juror 50 's conduct during the voir dire process. Any inquiry will be focused primarily on the testimony of Juror 50. The proposed redactions reduce the risk that his testimony will be tailored based on a preview of information central to the inquiry or otherwise tainted by outside information and influence.
The proposed redactions pertain to the following information:
- Juror 50's exact responses to the questions on his jury questionnaire, which is being kept temporarily under seal. See Dkt. 596 at 5, fn 1.
- Data about the responses of other jurors and potential jurors to the jury questionnaire.
- Details of investigative steps the defense has taken and evidence uncovered thus far.
- The defense's view of the underlying facts.
- The scope of the defense's requested discovery in advance of the hearing.
Very truly yours,
/s/
BOBBI C. STERNHEIM
Attachments (to be kept under seal pending the Court's decision regarding redactions)
cc: Counsel of Record
DOJ-OGR-00008962