Epstein Secrets

-cr-00330-AJN Document 342 Filed 10/13/21 Page 1 of 17 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. • • • • x S2 20 Cr. 330 (AJN) MEMORANDUM OF LAW IN SUPPORT OF GHISLAINE MAXWELL'S MOTION FOR INDIVIDUAL SEQUESTERED JURO

20 Cr. 330 (AJN) MEMORANDUM OF LAW IN SUPPORT OF GHISLAINE MAXWELL'S MOTION FOR INDIVIDUAL SEQUESTERED JUROR VOIR DIR

trial and (ii) the extensive prior negative publicity concerning Ghislaine Maxwell and Jeffrey Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of his death in August 2019 and the arrest of Ms. Maxwell in July 2020, has significantly increased t

Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of

rcised. This requires that the parties obtain sufficient information from the potential jurors upon which to base their challenges. United States v. Ledee, 549 F.2d 990, 993 (5th Cir.), cert. denied, 434 U.S. 902 (1977) ("Peremptory challenges are worthless if trial 10 EFTA00065536 Case 1:20-cr-003

wyer be given an opportunity to ferret out possible bias and prejudice of which the juror himself may be unaware until certain facts are revealed. Ledee, 549 F.2d at 993 (citing Frates and Greer, Jury Voir Dire: The Lawyer's Perspective, 2 A.B.A. Litigation No. 2 (1976)). Indeed, the Fifth Circuit la

UTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) MEMORANDUM OF LAW IN SUPPORT OF GHISLAINE MAXWELL'S MOTION FOR INDIVIDUAL SEQUESTERED JUROR VOIR DIRE AND LIMITED COUNSEL-CONDUCTED VOIR DIRE Christian R. Everdell COHEN & GRESSER LLP 800 Third Av

New York, NY 10007 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00011096 --- PAGE BREAK --- INTRO

trial and (ii) the extensive prior negative publicity concerning Ghislaine Maxwell and Jeffrey Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of his death in August 2019 and the arrest of Ms. Maxwell in July 2020, has significantly increased t

Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of

rcised. This requires that the parties obtain sufficient information from the potential jurors upon which to base their challenges. United States v. Ledee, 549 F.2d 990, 993 (5th Cir.), cert. denied, 434 U.S. 902 (1977) ("Peremptory challenges are worthless if trial 10 EFTA00011106 --- PAGE BREAK -

New York, NY 10007 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00011115 --- PAGE BREAK --- Case

UTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) MEMORANDUM OF LAW IN SUPPORT OF GHISLAINE MAXWELL'S MOTION FOR INDIVIDUAL SEQUESTERED JUROR VOIR DIRE AND LIMITED COUNSEL-CONDUCTED VOIR DIRE Christian R. Everdell COHEN & GRESSER LLP 800 Third Av

Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of

trial and (ii) the extensive prior negative publicity concerning Ghislaine Maxwell and Jeffrey Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of his death in August 2019 and the arrest of Ms. Maxwell in July 2020, has significantly increased t

rcised. This requires that the parties obtain sufficient information from the potential jurors upon which to base their challenges. United States v. Ledee, 549 F.2d 990, 993 (5th Cir.), cent. denied, 434 U.S. 902 (1977) ("Peremptory challenges are worthless if trial 10 EFTA00011125 --- PAGE BREAK -