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_ Case 1:20-cr-00330-PAE Document 635 _ Filed 03/01/22 Page1of4 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 March 1, 2022 BY EMAIL 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: In accordance with the Court’s February 24, 2022 Opinion and Order (Dkt. No. 620), the Government respectfully submits this letter to propose questions for the public hearing at which the Court will question Juror 50 under oath. The Court has ordered that the scope of the hearing will be limited to three narrow categories of inquiry: (1) whether Juror 50 provided false answers to Questions 25 and 48 on his juror questionnaire, (2) the explanation for the answers he gave to those particular questions, and (3) “how Juror 50 would have responded to follow-up questions if accurate answers had been provided.” Feb. 24, 2022 Opinion and Order at 7. As an initial matter, the Government submits that after placing Juror 50 under oath, the Court should give Juror 50 the following instruction consistent with Rule 606(b): Iam going to ask you a series of focused questions today. I instruct you not to tell me about the jury’s deliberations. I also instruct you not to tell me about your thought processes as a deliberating juror. None of my questions will ask you about those subjects. Following that instruction, the Government respectfully submits that the following questions would be appropriate for each of the above three categories. DOJ-OGR- 00009634