U.S. Department of Justice

United States Attorney  Eastern District of New York 

 

MKP

 

271 Cadman Plaza East

F. #2017R01840

 

 Brooklyn, New York 11201

April 2, 2019 By ECF The Honorable Nicholas G. Garaufis United States District Judge United States District Court 225 Cadman Plaza East Brooklyn, New York 11201 Re: United States v. Keith Raniere, et al. Criminal Docket No. 18-204 (NGG) Dear Judge Garaufis: The government respectfully submits this letter

attaching the government’s

 proposed juror questionnaire, which is largely agreed-upon by the parties. The parties will confer on Exhibit A and submit that to the Court no later than tomorrow. The government respectfully requests permission to provide the Court with proposed Exhibit A under seal  because it will contain the name of victims and others who have not been publicly identified. The parties also jointly request that the Court issue an order preventing public

release of prospective jurors and empaneled jurors’ names until after trial and requiring that

 jurors be identified only by juror number in open court. See United v. Shkreli, 15-CR-637

Case 1:18-cr-00204-NGG-VMS Document 491 Filed 04/02/19 Page 1 of 2 PageID #: 5128

 

 2 (KAM), Memorandum and Order, dated June 25, 2017, (Dkt. No. 259), at 16. The parties may also request a

dditional precautions be taken to protect jurors’ identities until after trial.

Respectfully submitted, RICHARD P. DONOGHUE United States Attorney By: /s/ Moira Kim Penza Tanya Hajjar Mark J. Lesko Assistant U.S. Attorneys (718) 254-7000 cc: Clerk of Court (NGG) (by ECF) Counsel of Record (by ECF)

Case 1:18-cr-00204-NGG-VMS Document 491 Filed 04/02/19 Page 2 of 2 PageID #: 5129

 

 JUROR NO. ________ Page 1 of 37

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK -----------------------------------------------------X

 

UNITED STATES OF AMERICA -v- 18 CR 204 (S-2) (NGG) KEITH RANIERE,

also known as “

Vanguard

,”

 

“

Grandmaster

,”

 and

“Master,”

CLARE BRONFMAN, ALLISON MACK, KATHY RUSSELL and LAUREN SALZMAN, Defendants. -----------------------------------------------------X HON. NICHOLAS G. GARAUFIS UNITED STATES DISTRICT JUDGE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK 225 CADMAN PLAZA EAST BROOKLYN, NEW YORK JURORS ARE INSTRUCTED TO CALL: 1-800-522-5100 ON [DATE], AFTER 7 P.M. FOR FURTHER REPORTING INSTRUCTIONS.

Case 1:18-cr-00204-NGG-VMS Document 491-1 Filed 04/02/19 Page 1 of 37 PageID #: 5130