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Case 1:20-cr-00330-PAE Document583_ Filed 01/25/22 Page5of5 464 U.S. 501, 505 (1984). Public scrutiny is essential to “enhance[] the quality and safeguard|] the integrity” of criminal trials. Globe Newspaper Co. v. Superior Ct. for Norfolk City, 457 U.S. 596, 606 (1982). Openness preserves and is essential to “public confidence in the administration of justice.” ABC, Inc. v. Stewart, 360 F.3d 90, 98 (2d Cir. 2004). Accordingly, we respectfully ask that the Court unseal Defendant’s Motion for a New Trial and the questionnaires for the twelve seated jurors. We also respectfully ask this Court to make clear that all subsequent documents filed related to this motion should be filed without sealing and with only the redactions necessary to adequately protect the safety of jurors and their identities. We thank the Court for its attention to this matter. Respectfully submitted, David WeCraw David E. McCraw ce: All counsel of record (via e-mail) DOJ-OGR-00008837