U.S. Department of Justice
U.S. Department of Justice
United States Attorney
Southern District of New York
The Sihlo J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
November 13, 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, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The parties respectfully submit this joint letter to provide the Court with the parties'
respective positions regarding juror questionnaires completed on November 12, 2021.
I. Prospective Jurors Proceeding to Voir Dire
The parties agree that the following prospective jurors should proceed to voir dire:
Juror #
570
573
578
581
582
583
586
589
593
594
595
596
602
604
608
611
612
EFTA00094667
Page 2
615
621
622
623
630
637
642
647
651
655
661
667
668
669
670
676
677
680
683
685
690
691
694
II. Prospective Jurors Excused
The parties agree that the following jurors should be excused:
Juror #
567
571
572
574
575
576
577
579
580
584
588
590
EFTA00094668
Page 3
591
592
597
600
601
603
605
606
607
610
613
614
616
619
624
626
627
628
629
632
633
634
635
636
638
640
641
643
644
646
649
650
653
654
657
658
663
664
665
666
671
672
EFTA00094669
Page 4
673
674
675
679
681
682
687
688
692
693
III. Defense Objections
The following is a list of prospective jurors that the defense but not the Government
believes should be excused:
Juror #
568
569
587
598
599
609
618
625
631
645
648
652
660
678
686
689
IV. Government Objections
The following is a list of prospective jurors that the Government but not the defense
believes should be excused:
EFTA00094670
Page 5
Juror II
585
617
620
639
656
659
662
684
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
By: s/
Assistant United States Attorneys
Southern District of New York
Cc: Defense Counsel (By email)
EFTA00094671
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[Image 1] The image shows a document that appears to be a letter or a notice from the United States Department of Justice. The document is addressed to a specific individual or entity, as indicated by the recipient's name and address. The date of the letter is November 14, 2011. The document includes a heading that reads "United States Department of Justice," followed by the name of the department and the a
[Image 2] The image appears to be a scanned document, specifically a page from a book or a report. The document contains text and numbered lists. The visible text includes headings such as "Page 1," "Defense," "Government," and "Government Objectives." There are also numbered lists under these headings, but the specific content of the lists is not clearly visible due to the resolution of the scan. The docum
[Image 3] The image shows a page from a document, which appears to be a legal or court-related paper. The document is titled "Page 2" and includes a heading that reads "Pregnancy Discrimination Act." Below the heading, there is a list of numbers, which seem to be case numbers or reference numbers for the cases being discussed. The document is structured with a left column and a right column, and there are t
[Image 4] The image shows a document with text and numbers. It appears to be a page from a legal or official document, possibly a court filing or a letter from a legal office. The text includes a header with the page number, a list of case numbers, and a section titled "RESPONSIBLY SUBMITTED, DATED:". Below this, there is a signature line with a name and a date, which is redacted. The document also contains
[Image 5] The image shows a page with a series of numbers listed vertically. The numbers are in a sequence that appears to be a list or a series of identifiers. The page is text-based and does not contain any images or graphics. The numbers are the main focus of the page, and there are no visible names, dates, places, or logos. The document type is not clearly identifiable from the image provided.