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Case 1:20-cr-00330-PAE Document596 - Filed 02/11/22 Page4of7 Accordingly, the Defendant’s motion to keep the papers under seal in their entirety is denied. Instead, the parties must propose narrowly tailored redactions as necessary to serve important interests. Here those interests are to ensure the integrity of any inquiry going forward and to protect juror anonymity and privacy. Those interests justify redaction of the questions the parties propose be asked at any hearing. See United States v. McCoy et al., No. 14 Cr. 6181 (EAW), Dkt. No. 312 (text order) (W.D.N.Y. May 26, 2017) (requiring proposed questions to be submitted directly to the court); see also Dkt. No. 329 at 38-39 (counsel discussing concern that disclosing specific questions ahead of hearing would allow juror to prepare and “rehearse the answers”). And they may justify redaction of any 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. The Court will also permit redactions necessary to ensure juror anonymity and privacy. See Press-Enter. Co. v. Superior Ct. of Cal., Riverside Cnty., 464 U.S. 501, 511-12 (1984). By contrast, there is no basis to redact legal arguments, case citations, and analysis regarding the standard by which the parties contend that the Defendant’s motion should be evaluated, as well as legal arguments, case citations, and analysis regarding the proper scope of any potential hearing. Nor will the Court permit the redaction of information that is widely reported in the press. Such redactions do not conform with the dictates of Lugosch and are not necessary to protect the integrity of any inquiry. Importantly, following the Court’s resolution of the Defendant’s motion or a hearing, if one is ordered, all redactions will be promptly unsealed except those necessary to protect any continuing interest in juror anonymity and privacy. The parties are thus ORDERED to propose narrowly tailored redactions to the Defense motion, the Government’s response in opposition, and the Defense reply, as consistent with this DOJ-OGR-00008912