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Case 1:20-cr-00330-PAE Document581 Filed 01/24/22 Page2of5 January 21, 2022 Page 2 are proper, and “such motions are common in this Circuit”); United States v. All Funds on Deposit at Wells Fargo Bank, 643 F. Supp. 2d 577, 580 (S.D.N.Y. 2009) (“A motion to intervene to assert the public’s First Amendment right of access to criminal proceedings is proper.”). The Miami Herald, as a news organization, “has a direct interest in collecting information about a matter of public interest in order to serve its function as a purveyor of news.” See Schiller v. City of New York, No. 04 CIV. 7921(KMK)(JC, 2006 WL 2788256, at *3 (S.D.N.Y. Sept. 27, 2006). Additionally, the interests of the Miami Herald are not likely to overlap with the Defendant or the Government, particularly where, as here, neither party is likely to support unsealing. /d. Finally, intervention “for the limited purpose of challenging strictures on the dissemination of information should not impede the progress of the [proceedings].” Jd. Ms. Brown and the Miami Herald therefore respectfully request that they be permitted to intervene for the limited purpose of opposing sealing of Ms. Maxwell’s motion for a new trial, the exhibits thereto, and any additional submissions on this issue. Il. Ms. Maxwell’s Motion for a New Trial and Exhibits Should Be Unsealed. Ms. Maxwell’s motion for a new trial is a judicial record entitled to a presumption of public access. Documents filed with the Court that are “relevant to the performance of the judicial function and useful in the judicial process” are judicial documents. See United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995) [hereinafter “Amodeo I]; Brown v. Maxwell, 929 F.3d 41, 49 (2d Cir. 2019). Judicial documents are subject to a presumption of public access. Amodeo I, 44 F.3d at 146. Specifically, “[d]ocuments filed in criminal cases used to determine a litigant’s substantive legal rights are judicial documents[,|” including motions for a new trial. United States v. Donato, DOJ-OGR-00008825