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Case 1:20-cr-00330-PAE Document558 _ Filed 12/19/21 Page3of5 Second, the parties believe that either alternative would interfere with the parties’ ability to present their case to the jury and advocate effectively for their clients. Whether the interruption is caused by the need for the jurors to find a page in their binders or for court staff to turn monitors on and off, the interruption would have a significant and detrimental effect on the ability of the parties to present their case efficiently and effectively to the jury. Given the significance of closing argument to the parties’ presentations to the jury, this interference undermines the parties’ core interests. Finally, and specifically with regard to toggling screens on and off, presenting slides to the jury and the public that contain sealed material poses risks to the privacy interests of victims and third parties. If a screen remains active through natural human error—on the part of the parties or the courthouse staff—it would result in the publicization of sealed material. For those reasons, the parties believe that the use of binders or toggling screens during closing argument is unworkable. The parties also considered giving the jurors printed versions of their presentations in lieu of binders. Doing so is unworkable for two reasons. First, as the Court also likely observed during trial, jurors move at different rates through the paper material placed before them. It will be difficult for counsel to ensure that no jurors are falling behind or moving ahead during the closing arguments. Second, to the extent the defense would like to adjust their slides in response to the Government’s closing argument, that ability is compromised if the defense must also have their slides printed for the jury immediately upon the conclusion of the Government’s argument. Accordingly, the parties propose that they will provide a copy of their slides, without any sealed material, to the public tomorrow as soon as the parties have had adequate time to review DOJ-OGR-00008441