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Case 1:20-cr-00330-PAE Document 636 Filed 03/01/22 Page1of22 800 Third Avenue New York, NY 10022 COHEN & GRESSER LLP +1 212.957 7600 phone www.cohengresser.com Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com 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, NY 10007 Re: United States v. Ghislaine Maxwell, 82 20 Cr. 330 (AJN) Dear Judge Nathan: We write in response to the Court’s order, dated February 24, 2022, permitting the parties to submit proposed questions to the Court for the hearing related to Ms. Maxwell’s Motion for a New Trial. Dkt. 610. Renewed Request for Counsel to Conduct the Questioning of Juror 50 Ms. Maxwell reiterates her request that the Court allow counsel to conduct the questioning of Juror 50 during the upcoming hearing. Attorney-conducted questioning enhances the opportunity and ability to elicit bias on the part of the juror. See, e.g., Johnson & Haney, Felony Voir Dire: An Exploratory Study of its Contents and Effect, 18 Law and Human Behavior 309 (1994). To smoke out the reasons why Juror 50 did not truthfully answer Questions 48 and 25 on the jury questionnaire, he must be cross-examined. Defense counsel is in the best position to conduct that cross-examination. This was the procedure that Judge Pauley followed in United States v. Daugerdas, and there is no reason to follow a different procedure here. See Dkt. 616-1. 2100689.3 DOJ-OGR- 00009638