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Case 1:20-cr-00330-PAE Document569_ Filed 01/05/22 Page1of3 a = 800 Third Avenue | COHEN & GRESSER LLP New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com January 5, 2021 BY EMAIL 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, S2 20 Cr. 330 (AJN) Dear Judge Nathan: We write concerning an issue of pressing importance. It has come to the attention of the defense that one of the twelve jurors in this case (the “Juror”) has been giving oral and videotaped interviews to various members of the press concerning the jury deliberations. These interviews have been publicly reported in several media outlets.' Among other things, the Juror told reporters that he disclosed to the other members of the jury during deliberations that he was a victim of sexual abuse and further described his memory of those events. According to the Juror, his disclosure influenced the deliberations and convinced other members of the jury to convict Ms. Maxwell. ! See Lucia Osborne-Crowley, “‘They were all believable’: Maxwell juror says jury was convinced by accusers’ accounts of a pattern of abuse,” The Independent (Jan. 4, 2022); Laura Collins and Daniel Bates, “Ghislaine was a predator as guilty as Epstein’: Maxwell juror describes moment he ‘locked eyes’ with sex trafficker and reveals his own abuse ordeal,” Daily Mail (Jan. 5, 2022), available at https:/Avww.dailymail.co.uk/news/article- 10370193/Ghislaine-Maxwell-juror-says-evidence-convinced-panel-predator.html; Luc Cohen, “Some Ghislaine Maxwell jurors initially doubted accusers, juror says,” Reuters (Jan. 5, 2022). 2070301.1 DOJ-OGR-00008801