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Case 1:20-cr-00330-PAE Document 342 Filed 10/13/21 Page5of17 Individual voir dire is appropriate and within the court’s discretion in cases like this where the potential jury pool has been exposed to extensive pretrial publicity and may harbor prejudice against the defendant, and where the allegations touch on issues that are potentially inflammatory. See Stewart, 433 F.3d at 303; see also United States v. Rahman,189 F.3d 88, 122 (2d Cir. 1999). Using individual voir dire, in addition to a juror questionnaire, is necessary in this case (1) to expose potential biases by maximizing the likelihood that members of the venire will respond honestly to questions, and (i1) to avoid contaminating unbiased members of the venire when other members disclose prior knowledge of prejudicial information or blurt out a prejudicial remark. As the Supreme Court has stated: It may sometimes be necessary to question on voir dire prospective jurors individually or in small groups, both to maximize the likelihood that members of the venire will respond honestly to questions conceming bias, and to avoid contaminating unbiased members of the venire when other members disclose prior knowledge of prejudicial information. Nebraska Press Ass’n v. Stuart, 427 U.S. 539, 602 (1976). Il. THE JURY POOL HAS BEEN AND WILL CONTINUE TO BE EXPOSED TO SUBSTANTIAL PRETRIAL PUBLICITY ABOUT GHISLAINE MAXWELL, JEFFREY EPSTEIN, AND THIS CASE A. A Tsunami of Pretrial Publicity About this Case Countless articles, books, podcasts, television shows, and docuseries from various sources have been published and broadcast concerning this case since it was filed in July 2020. This followed closely on the heels of an avalanche of media reports preceding and following Epstein’s arrest in July 2019 and following his death in August 2019. A tsunami of reporting in every conceivable form — newspapers, magazines, books, television, radio, video streaming services, podcasts, social media platforms — has broadcast this case locally, nationally, and globally. Without a doubt, and without any credible evidentiary basis, Ms. Maxwell has been DOJ-OGR-00005210