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Case 1:20-cr-00330-PAE Document 597 WINSTON &STRAWN LLP North America Europe Asia February 9, 2022 VIA ELECTRONIC MAIL Hon. Alison J. Nathan United States District Court Southern District of New York 40 Foley Square, Room 2102 New York, NY 10007 Filed 02/11/22 Re: United States v. Maxwell, No. 1:20-cr-00330-AJN Dear Judge Nathan: Page 3 of 5 1901 L Street, NW Washington, DC 20036 T +1202 282 5000 F +1 202 282 5100 We write on behalf of our client, the National Association of Criminal Defense Lawyers (NACDL), regarding the above-referenced action pending before you. We respectfully request leave from the Court to file a brief amicus curiae on the issue of the impact of the post-trial revelations and admissions from Juror # 50 on whether the Defendant in this case received the guaranteed right to a fair trial and what relief is required. Specifically, NACDL would address the increased importance of written or oral voir dire in high-profile criminal cases and/or those with sensitive issues central to a case that could reflect a juror’s bias or potential for extraneous issues being brought into jury deliberations, the impact of inaccurate answers to questions asked to expose potential bias for further questioning and the exercise of strikes, whether and when a court should consider the deliberateness in a potential juror providing inaccurate information and the process by which such issues should be explored once they have been disclosed. In support of this request to file a brief amicus curiae, proposed amici state the following: 1. NACDL is a nonprofit voluntary professional bar association made up of and working on behalf of criminal defense attorneys to ensure justice and due process for those accused of crime or misconduct. DOJ-OGR-00008918