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Case 1:20-cr-00330-PAE Document 342 Filed 10/13/21 Page3of17 Netflix, Peacock, and Amazon; in podcasts and YouTube recordings; in social media sites, such as Facebook, Instagram, Twitter; in online sites, chat rooms and blogs. The publicity has covered a wide range of topics including and beyond those that will be presented at trial. Prospective jurors may also have a strong reaction to the sensitive nature of the charges and some of the evidence that to be adduced at trial. Epstein’s arrests and prior conviction for sexual misconduct, allegations of his sexual misconduct of minors over the course of two decades, and his untimely death awaiting his federal trial will be front and center during Ms. Maxwell’s upcoming trial. The standard voir dire typically conducted by the Court is insufficient for this case and will be redundant to questions posed in the proposed jury questionnaire. A written questionnaire coupled with sequestered voir dire of individual prospective jurors and limited open-ended questioning by counsel will assist the Court and parties in determining whether prospective jurors have developed prejudicial preconceptions regarding this case, Ms. Maxwell, and Epstein due to this intense media coverage and pretrial publications and broadcasts. DOJ-OGR-00005208