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Case 22-1426, Document 1-2, 07/08/2022, 3344417, Page81 of 91 02/17/2022 MEMO ENDORSEMENT as to Ghislaine Maxwell on MOTION FOR LEAVE TO FILE AN AMICUS CURIAE BRIEF. ENDORSEMENT: The request for leave to file an amicus brief in accordance with this Court's February 11, 2022 order is GRANTED. SO ORDERED. (Signed by Judge Alison J. Nathan on 2/17/2022) (Inl) (Entered: 02/17/2022) 02/18/2022 ORDER as to Ghislaine Maxwell: The parties are hereby ORDERED to re-submit via email revised redactions to the parties' briefing on the Defendant's motion for a new trial by February 22, 2022. The revised proposed redactions shall be consistent with this Order. SO ORDERED. (Signed by Judge Alison J. Nathan on 2/18/2022) (Inl) (Entered: 02/18/2022) 02/21/2022 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C Sternheim dated 02/21/2022 re: Letter in Response to Dkt. 605 (Sternheim, Bobbi) (Entered: 02/21/2022) 02/24/2022 ORDER as to Ghislaine Maxwell: The Court is in receipt of the Defendant's proposed redactions revised in response to this Court's order. See Dkt. Nos. 605, 606. The Court has reviewed the proposed redactions and concludes that they are in accordance with its prior orders. See Dkt. Nos. 596, 605. The narrowly tailored redactions further the important interests of helping ensure the integrity of any inquiry and maintaining juror anonymity and privacy. As the Court explained in its February 11 Order, these interests justify redaction of the questions the parties propose be asked at any hearing and specific factual information developed by the parties that has not been publicly reported in the press and that the parties propose be inquired about at any forthcoming hearing. Dkt. No. 596 at 4 (citing United States v. McCoy et al., No. 14 Cr. 6181 (EAW), Dkt. No. 312 (text order) (W.D.N.Y. May 26, 2017); id. Dkt. No. 329 at 38-39; Press—Enter. Co. v. Superior Ct. of Cal., Riverside Cnty., 464 U.S. 501, 511-12 (1984)). Accordingly, the parties are ORDERED to docket the redacted briefs, accompanying exhibits, and their January 13 letters, by February 25, 2022. The Court will docket Juror 50's motion. As noted in its prior Order, following the Court's resolution of the Defendant's motion or a hearing, all redactions will be promptly unsealed except those necessary to protect any continuing interest in juror anonymity and privacy. See United States v. Amodeo, 44 F.3d 141, 146—47 (2d Cir. 1995); see also Press—Enter. Co., 478 U.S. at 14. (Signed by Judge Alison J. Nathan on 2/24/2022) (ap) (Entered: 02/24/2022) 02/24/2022 8 | NOTICE OF MOTIONTO INTERVENE AND FOR THE RELEASE OF DOCUMENTS UNDER SEAL. Document filed as to Ghislaine Maxwell. (ap) (Entered: 02/24/2022) 02/24/2022 MEMORANDUM OF LAW IN SUPPORT OF MOTION TO INTERVENE AND FOR RELEASE OF SEALED JURY QUESTIONNAIRE AND TRANSCRIPT, ON BEHALF OF PROPOSED INTERVENOR, JUROR 50 as to Ghislaine Maxwell re: 608 MOTION. (ap) (Entered: 02/24/2022) 02/24/2022 aN 10 | ORDER as to Ghislaine Maxwell: for the reasons fully explained in the Opinion & Order, a hearing is necessary to resolve the Defendant's motion. Because of the important interest in the finality of judgments, the standard for obtaining a post—verdict hearing is high. The Court concludes, and the Government concedes, that the demanding standard for holding a post—verdict evidentiary hearing is met as to whether Juror 50 failed to respond truthfully during the jury selection process to whether he was a victim of sexual abuse. Following trial, Juror 50 made several direct, unambiguous statements to multiple media outlets about his own experience that do not pertain to jury deliberations and that cast doubt on the accuracy of his responses during jury selection. Juror 50's post-trial statements are "clear, strong, substantial and incontrovertible evidence that a specific, non—speculative impropriety"namely, a false statement during jury selection has occurred. United States v. Baker, 899 F.3d 123, 130 (2d Cir. 2018). To be clear, the potential impropriety is not that someone with a history of sexual abuse may have served on the jury. Rather, it is the potential failure to respond truthfully to questions during the jury selection process that asked for that material information so that any potential bias could be explored. In contrast, the demanding standard for ordering an evidentiary hearing is not met as to the conduct of any other juror. The Court DENIES the request to conduct a hearing with respect to the other jurors. The Court also DENIES the Defendant's request for a broader hearing and pre-hearing discovery. The Court therefore ORDERS that a hearing take place at DOJ-OGR- 00020467