590.pdf

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pdf

Source set

house-oversight-doj

Pages

9

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Searchable text available

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0.9421332746395629

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Case 1:20-cr-00330-PAE Document590 _ Filed 02/01/22 Page1of9 800 Third Avenue New York, NY 10022 COHEN & GRESSER LLP +1 212.957 7600 phone www.cohengresser.com Christian R. Everdell +1 (212) 957-7600 [email protected] February 1, 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, NY 10007 Re: United States v. Ghislaine Maxwell, 82 20 Cr. 330 (AJN) Dear Judge Nathan: We write in response to the Court’s order, dated January 26, 2022, requiring the defense to file a letter on the public docket justifying our request to seal Ms. Maxwell’s Motion for a New Trial and accompanying exhibits (collectively, the “Motion’”) under the three-part test in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Dkt. 585. Introduction The Motion urges the Court to right a grievous wrong that deprived Ms. Maxwell of a fundamental constitutional right — her right to be tried by a fair and impartial jury. Juror 50’s responses to the jury questionnaire and questions posed to him during in-person voir dire corrupted the voir dire process and violated Ms. Maxwell’s right to a fair trial. As set forth in the Motion, the defense believes that the existing record is clear and more than sufficient for the Court to grant Ms. Maxwell a new trial without the need for further factual development. Should the Court agree with the defense, the Motion could be unsealed and publicly docketed at the same time the Court issues its ruling with no additional delay. 2087306.1 DOJ-OGR-00008852 

Case 1:20-cr-00330-PAE Document590 _ Filed 02/01/22 Page2of9 The Honorable Alison J. Nathan February 1, 2022 Page 2 Should the Court determine that a hearing is necessary, however, the Motion should remain sealed until the conclusion of the hearing. With such a vital constitutional interest at stake, it is of paramount importance for the Court to ensure the integrity of any fact-gathering process t…

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