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_ Case 1:20-cr-00330-PAE Document 355 Filed 10/18/21 Page1of5 oN U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew’s Plaza New York, New York 10007 October 18, 2021 BY ECF 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 Government respectfully submits this letter pursuant to the Court’s Order dated October 14, 2021 (Dkt. No. 343) directing the Government to respond to the defendant’s motion for an order granting limited counsel-conducted voir dire and individual sequestered voir dire (Dkt. No. 341). 1. Attorney Voir Dire Is Not Warranted None of the defendant’s arguments warrant departing from the well-settled practice in this District of Court-led voir dire. The Court is well-equipped to thoroughly question prospective jurors and to appropriately filter questions prepared by the parties. It is well established that “[a] district court is ‘accorded ample discretion in determining how best to conduct .. . voir dire.’” United States v. Lawes, 292 F.3d 123, 128 (2d Cir. 2002) (quoting Rosales-Lopez v. United States, 451 U.S. 182, 189 (1981)); accord United States v. Quinones, 511 F.3d 289, 299 (2d Cir. 2007). As a general matter, “[v]Joir dire is necessarily a matter in which the trial court has extremely broad discretion,” and “federal trial judges are not required to ask every question that counsel—even all counsel—believes is appropriate.” Lawes, DOJ-OGR-00005250