Case 1:20-cr-00330-PAE Document595- Filed 02/08/22 Page1ofi1 LAW OFFICES OF BOBBI C. STERNHEIA\ 212-243-1100 * Main 225 Broadway, Suite 715 917-912-9698 * Cell New York, NY 10007 888-587-4737 ° Fax [email protected] February 8, 2022 Honorable Alison J. Nathan United States District Court United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan: In response to the Court’s order, dated January 26, 2022 (Dkt. 585), and for the reasons stated in the defense letter, dated February 1 (Dkt. 590) (annexed hereto for convenience), Ghislaine Maxwell requests that the government’s response and accompanying exhibits in opposition to Ms. Maxwell’s Motion for a New Trial (“Motion”) (dated February 2, 2022) remain under seal until the Court decides the pending Motion or until the conclusion of any hearing held on the Motion. With the constitutional right to a fair trial at stake, it is of paramount importance for the Court to ensure the integrity of any fact-gathering process that may take place so that the inquiry is safeguarded and can uncover the truth of what happened. Public filing of Ms. Maxwell’s Motion, the government’s response, and Ms. Maxwell’s reply (to be filed on February 9) places those principles at risk. Giving Juror 50 a preview of information he does not have and should not have at this juncture would permit him to craft testimony, destroy critical evidence, and explain away facts to protect himself while further jeopardizing the integrity of this case. The absence of this temporary safeguard will contribute to further obstruction of the truth-seeking process, compromising any factual inquiry ordered by the DOJ-OGR- 00008898