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Case 1:20-cr-00330-PAE Document581 Filed 01/24/22 Page3of5 January 21, 2022 Page 3 714 F. App’x 75, 76 (2d Cir. 2018) (finding exhibits attached to a motion for a new trial “determined the codefendant’s substantive legal rights” and were therefore judicial documents). Ms. Maxwell’s motion for a new trial, and the exhibits attached to it, are judicial records, subject to a presumption of openness. /d.; see also Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 113-14 (2d Cir. 2006) (applying the same presumption to a motion’s attachments as the motion itself, finding that “[o]nce those submissions come to the attention of the district judge, they can fairly be assumed to play a role in the court’s deliberations”). “A qualified First Amendment right of access applies to criminal proceedings.” Donato, 714 F. App’x at 76. “Once a First Amendment right to access to judicial documents is found, the documents may be sealed [only] if specific, on the record findings are made demonstrating that closure is essential to preserve higher values and is narrowly tailored to serve that interest.” Jd. Ms. Maxwell shields even her reasoning for requesting that the motion be sealed, stating only that she requests that all submissions pertaining to Juror No. 50 remain sealed “[flor the reasons set forth in the Motion” (which, of course, is sealed). See Dkt. 580. However, it is evident that much of the information about Juror No. 50 is already public, having been widely reported in not only national but global media. The juror’s first and middle names have been reported in countless media outlets.' He has given multiple interviews, including on-camera without any ! See, e.g., “Ghislaine Maxwell formally makes bid for new trial in sex trafficking case,” Miami Herald, (Jan. 20, 2022, https://www.miamiherald.com/news/local/crime/article257560713.html; “Some Ghislaine Maxwell jurors initially doubted accusers, juror says,” Reuters (Jan. 5, 2022), https://www.reuters.com/world/us/some-ghislaine- maxwell-jurors-initially-doubted-accusers-juror-says-2022-01-05/; “Maxwell Seeks New Trial After Juror Reveals Abuse History,” Bloomberg (Jan. 20, 2022), https://www.bloomberg.com/news/articles/2022-01-20/ghislaine- maxwell-seeks-new-trial-in-sex-trafficking-case. DOJ-OGR-00008826