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Case 1:20-cr-00330-PAE Document 342 Filed 10/13/21 Page2of17 INTRODUCTION Defendant Ghislaine Maxwell submits this memorandum of law in support of her motion for individual sequestered voir dire of prospective jurors and limited attorney-conducted voir dire. PRELIMINARY STATEMENT The Court has already determined that a juror questionnaire is appropriate in this case. Pursuant to the Court’s order, the parties recently submitted, under seal, a joint proposed jury questionnaire. The Court has scheduled three days for prospective jurors to complete the final Court-approved questionnaire, and four days to conduct examination of prospective jurors. But a questionnaire by itself is not sufficient in this case to root out potential juror bias and to permit the attorneys to exercise intelligent peremptory challenges. Supplementing a robust questionnaire with individual sequestered voir dire and limited examination of jurors by counsel is necessary in this case because of the sensitive subject matter of the charges and two types of unfairly prejudicial media attention: (i) the pretrial publicity that this case has received and will continue to receive throughout the duration of the trial and (11) the extensive prior negative publicity concerning Ghislaine Maxwell and Jeffrey Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of his death in August 2019 and the arrest of Ms. Maxwell in July 2020, has significantly increased the likelihood that prospective jurors will report to jury selection with preconceptions, impressions, and opinions about the conduct at issue in the trial and those accused of the charges in the indictment: Ms. Maxwell and Epstein An unprecedented amount of media coverage has focused on this case, Ms. Maxwell and Epstein. The publicity includes extensive coverage in the press, including newspapers, magazines, and on-line sites; in broadcast media, including regular and cable television stations, radio, and streaming platforms, such as DOJ-OGR-00005207