{
  "document_metadata": {
    "page_number": "1",
    "document_number": "356",
    "date": "10/18/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 356 Filed 10/18/21 Page 1 of 1\nLAW OFFICES OF BOBBI C. STERNHEIM\n212-243-1100 * Main\n917-912-9698 * Cell\n888-587-4737 * Fax\n225 Broadway, Suite 715\nNew York, NY 10007\nbcsternheim@mac.com\nOctober 18, 2021\nHonorable Alison J. Nathan\nUnited States District Judge\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell\nS2 20 Cr. 330 (AJN)\nDear Judge Nathan:\nThere is nothing surprising about the government's opposition to limited attorney-conducted voir dire and individual sequestered voir dire. (Dkt. 355.) The government's response is standard SDNY operating procedure: \"We don't do that here.\" Rarely is there an AUSA who has ever conducted voir dire, so it is easy to just say \"no.\" In this case, counsel are better positioned to address particular areas of case-related bias than is the Court, and requesting a mere minute per juror is far from onerous.\nThe proposed questionnaire seeks highly sensitive and personal information regarding each juror. Simply asking jurors to raise their hand in response to an invitation to speak privately on a personal topic is revealing and invasive. One would hope that the government would be sensitive to that fact and would want to ensure that a fair and impartial jury will be seated in this high-profile case. With each passing day, the amount of public exposure this case receives erodes that possibility. Below are today's Google search results:\n- Ghislaine Maxwell: \"about 4,740,000 (about 0.89 seconds)\"\n- Jeffrey Epstein: \"about 26,200,000 results (0.86 seconds)\"\nThe Court has the power and the obligation to ensure that jury selection eliminates jurors who are biased and/or motivated to serve for reasons beyond being fair and impartial.\nThis is an extraordinary case involving sensitive issues. We urge the Court to exercise its supervisory powers and discretion and grant the defense request for individual sequestered voir dire and very limited counsel-conducted voir dire.\nVery truly yours,\n/s/\nBOBBI C. STERNHEIM\ncc: All Counsel\nDOJ-OGR-00005255",
  "text_blocks": [
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      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 356 Filed 10/18/21 Page 1 of 1",
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    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM\n212-243-1100 * Main\n917-912-9698 * Cell\n888-587-4737 * Fax\n225 Broadway, Suite 715\nNew York, NY 10007\nbcsternheim@mac.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "October 18, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Honorable Alison J. Nathan\nUnited States District Judge\nUnited States Courthouse\n40 Foley Square\nNew York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell\nS2 20 Cr. 330 (AJN)",
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    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "There is nothing surprising about the government's opposition to limited attorney-conducted voir dire and individual sequestered voir dire. (Dkt. 355.) The government's response is standard SDNY operating procedure: \"We don't do that here.\" Rarely is there an AUSA who has ever conducted voir dire, so it is easy to just say \"no.\" In this case, counsel are better positioned to address particular areas of case-related bias than is the Court, and requesting a mere minute per juror is far from onerous.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The proposed questionnaire seeks highly sensitive and personal information regarding each juror. Simply asking jurors to raise their hand in response to an invitation to speak privately on a personal topic is revealing and invasive. One would hope that the government would be sensitive to that fact and would want to ensure that a fair and impartial jury will be seated in this high-profile case. With each passing day, the amount of public exposure this case receives erodes that possibility. Below are today's Google search results:\n- Ghislaine Maxwell: \"about 4,740,000 (about 0.89 seconds)\"\n- Jeffrey Epstein: \"about 26,200,000 results (0.86 seconds)\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Court has the power and the obligation to ensure that jury selection eliminates jurors who are biased and/or motivated to serve for reasons beyond being fair and impartial.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "This is an extraordinary case involving sensitive issues. We urge the Court to exercise its supervisory powers and discretion and grant the defense request for individual sequestered voir dire and very limited counsel-conducted voir dire.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Very truly yours,\n/s/\nBOBBI C. STERNHEIM",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "cc: All Counsel",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005255",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Jeffrey Epstein",
      "Bobbi C. Sternheim"
    ],
    "organizations": [
      "Law Offices of Bobbi C. Sternheim",
      "United States District Court"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "October 18, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 356",
      "S2 20 Cr. 330 (AJN)",
      "Dkt. 355",
      "DOJ-OGR-00005255"
    ]
  },
  "additional_notes": "The document is a letter from Bobbi C. Sternheim to Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter discusses the government's opposition to limited attorney-conducted voir dire and individual sequestered voir dire."
}