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Case 1:20-cr-00330-PAE Document 609 Filed 02/24/22 Page9of13 intervention in criminal cases by third parties who are seeking to prevent the wide dissemination of confidential or privileged information. United States v. RMI Co., 599 F.2d 1183 (3d Cir. 1979); United States v. Crawford, 735 F.2d 174 (Sth Cir. 1984); United States v. Martoma, 962 F. Supp. 2d 602, 605-06 (S.D.N.Y. 2013). “A third-party’s reasonable assertion of privilege with respect to documents to be produced in a criminal action is sufficient grounds on which to grant the third-party’s motion to intervene and to consider the merits of that party’s application.” Martoma, 962 F. Supp. 2d at 605-06. B. Juror 50’s Jury Questionnaire should be released to Counsel, but otherwise remain under seal, to provide Juror 50 with a full and fair opportunity to present his position to this Court 1. A copy of the Jury Questionnaire is necessary to comply with Judge Nathan’s January 5" order It is necessary for Juror 50 to review his answers to the Jury Questionnaire and the transcript of his voir dire testimony, before he is able to comply with Judge Nathan’s order and address the “appropriateness of an inquiry”, into his conduct and his truthfulness of his responses on the Jury Questionnaire. See Order at 1. Jan. 5, 2022. 20-CR-330. It should go without saying that Juror 50 needs to know whether or not the question(s) related to prior sexual abuse were answered by him correctly on his Jury Questionnaire to help determine what an appropriate inquiry would entail, so that the same would also Juror 50’s privacy rights and legitimate interests related to these matters. DOJ-OGR- 00008988