DOJ-OGR-00008975.jpg

648 KB

Extraction Summary

4
People
3
Organizations
2
Locations
2
Events
2
Relationships
3
Quotes

Document Information

Type: Legal correspondence / court filing
File Size: 648 KB
Summary

This document is a letter dated February 21, 2022, from defense attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. Sternheim explains that attached documents concerning a Motion for a New Trial contain proposed redactions to protect the integrity of an inquiry into 'Juror 50's conduct' and to protect the privacy of other jurors involved in the voir dire process.

People (4)

Name Role Context
Bobbi C. Sternheim Defense Attorney
Author of the letter representing Ghislaine Maxwell
Alison J. Nathan United States District Judge
Recipient of the letter, presiding judge
Ghislaine Maxwell Defendant
Subject of the case (United States v. Ghislaine Maxwell)
Juror 50 Juror
Subject of inquiry regarding conduct during voir dire process

Organizations (3)

Name Type Context
Law Offices of Bobbi C. Sternheim
Author's firm
United States District Court
Venue of the case
DOJ
Department of Justice (indicated by Bates stamp DOJ-OGR)

Timeline (2 events)

February 21, 2022
Filing of Document 606 in Case 1:20-cr-00330-PAE
New York, NY
Unknown (Prior to Feb 21, 2022)
Voir dire process involving Juror 50
Court

Locations (2)

Location Context
Address of Law Offices of Bobbi C. Sternheim
Address of United States Courthouse

Relationships (2)

Bobbi C. Sternheim Legal Counsel Ghislaine Maxwell
Sternheim writes on behalf of the defense in United States v. Ghislaine Maxwell
Alison J. Nathan Judge/Defendant Ghislaine Maxwell
Case caption and salutation

Key Quotes (3)

"The proposed redactions are intended to ensure the integrity of the fact-finding process to uncover the truth surrounding Juror 50’s conduct during the voir dire process"
Source
DOJ-OGR-00008975.jpg
Quote #1
"preserve specific factual information developed by the defense that has not been publicly reported"
Source
DOJ-OGR-00008975.jpg
Quote #2
"risks compromising the integrity of the jury selection process and the willingness of potential jurors to disclose personal information"
Source
DOJ-OGR-00008975.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (1,760 characters)

Case 1:20-cr-00330-PAE Document 606 Filed 02/21/22 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 21, 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, previously submitted under seal, contain proposed redactions in conformance with the Court’s Orders (Dkt. 596, 605).1
The proposed redactions are intended to ensure the integrity of the fact-finding process to uncover the truth surrounding Juror 50’s conduct during the voir dire process, to ensure juror anonymity and privacy, and to preserve specific factual information developed by the defense that has not been publicly reported and that the defense proposes to inquire about at any forthcoming hearing.
In an abundance of caution, we have proposed redactions to information and data about the responses of other jurors (selected and prospective) to the jury questionnaire because the questionnaires and sealed portions of the voir dire transcript are not part of the public record. The public disclosure of juror information, even if provided anonymously, risks compromising the integrity of the jury selection process and the willingness of potential jurors to disclose personal information.
Very truly yours,
/s/
BOBBI C. STERNHEIM
Attachments
cc: Counsel of Record
1 The documents - Ghislaine Maxwell’s Motion for a New Trial, the Government’s Opposition, and Ms. Maxwell’s Reply - will remain under seal pending the Court’s decision regarding the proposed redactions.
DOJ-OGR-00008975

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