This is an email chain between prosecutors and defense attorneys in the Ghislaine Maxwell criminal trial, dated November 7, 2021, discussing jury selection and proposed strikes of prospective jurors.
This document captures behind-the-scenes coordination during jury selection for United States v. Ghislaine Maxwell. The emails show prosecutors (including Christian Everdell) and defense attorney Bobbi Menninger exchanging lists of proposed juror strikes and preparing a joint letter to the court. Notably, the government withdrew objections to three jurors (numbers 127, 151, and 458) and agreed to proceed with those individuals to voir dire. The correspondence reveals the routine procedural work of reviewing hundreds of juror questionnaires (numbered 1-566) and categorizing them into joint keeps, joint strikes, and party-specific strikes.
From: To: Menninger Cc: Jeff Pa liuca Ann uni.erg Subject: RE: [EXTERNAL] RE: questionnaires Date: Sun, 07 Nov 2021 21:49:12 +0000 Attachments: 2021-11-08 joint_letter_regardingjuror_questionnaires.pdf Attached is a draft of a joint letter. Please let us know if you have any edits — we'll check for accuracy on our end as well, but we wanted to circulate so that we could all check at the same time. Please note that, for three jurors, we've withdrawn our objection and joined your position that those jurors should proceed to voir dire. Those juror numbers are: 127, 151, and 458. Thanks, Menninger November 7 2021 3:03 PM Ann Lundberg Subject: RE: [EXTERNAL] RE: questionnaires Sorry Mut we did not use Excel to prepare our list, so I don't know how to convert it. There may be a way to convert the pdf to Excel. From: Sent: Sunday, November 7, 2021 11:54 AM To: Menninger Cc: Ann Lundberg Subject: RE: EXTERNAL RE: questionnaires eff Pagliucj With apologies for the delay (we ran into an excel glitch), I'm attaching our current list of proposed strikes. Could you please send us your list in excel? It makes merging the two lists faster. Thanks! From: Menninger Sent: Sunday, November 7, 2021 1:03 PM To: < > eff Pagliuca (I EFTA00018893
Ann Lundberg u je : : : ques ionnaires Please find attached Defendant's position on jurors 1-566. As I understand it, you will be putting ours into the categories described by the Court (joint keeps, joint strikes, gov't only strikes and defense only strikes) and then re-circulating so that we can both check to ensure ours are entered correctly. Let me know if you have any questions. Thanks, From Sent: Sunday, November 7, 2021 10:57 AM To: Menninger Cc: Subject: Re: [EXTERNAL] RE: questionnaires eff Pagliuca Thanks very much, sounds good, just let us know when you're ready. On Nov 7, 2021, at 12:11 PM, Menninger Thanks= We are finalizing ours as well and should be done shortly. From: Sent: Sunday, November 7, 2021 10:08 AM To: Subject: RE: questionnaires Hi Chris, Menninger wrote: Jeff Pagliuca That's fine, we've completed our review and our paralegal is compiling a list to send over, which shouldn't take much longer. Thanks From: Christian Everdell Sent: Sunda November 7 20211:06 AM To: Menninger ;Jeff Pagliuca EFTA00018894
Cc: Subject: [EXTERNAL] RE: questionnaires We are still planning to send you our strikes by noon. But we would like to have a simultaneous exchange of strike lists. Please send us your list at noon as well. Thanks, Chris From: Christian Everdell Sent: Saturday, November 6, 2021 2:30 PM To: elf Pagliuca Cc: Subject: RE: questionnaires That's fine, M . We should be able to get you our strikes by then. Thanks. From: Sent: Saturda November 6 2021 12:53 PM To: Christian Everdell • • Jeff Pagliuca u ect: questionnaires All, Menninger Menninger Our joint submission is due to the Court tomorrow outlining four categories of juror numbers. We're happy to take on the task of compiling data for our joint submission. To that end, could you please email us your list of strikes by noon tomorrow? Once we receive your list, we will compile that data into a letter outlining the four categories of juror numbers the Court has requested, and we'll send that back to you so that you can double check the accuracy of the chart. We estimate that process will take a fair amount of time, which is why we'll need your data by noon tomorrow if you'd like us to coordinate the process. Thanks, Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 EFTA00018895