DOJ-OGR-00008990.jpg
Extracted Text (OCR)
Case 1:20-cr-00330-PAE Document609_ Filed 02/24/22 Page1i1of13
3. The instance matter presents a compelling reason to release
the Jury Questionnaire to Counsel, under seal.
To the extent Juror 50’s privacy interest would normally prevent disclosure, those factors
do not apply to the release of the Jury Questionnaire and the voir dire transcript, under seal, to
his own attorney. Such a release will allow Juror 50 to comply with Judge Nathan’s Order from
January 05, 2022. Additionally, since the Jury Questionnaire and voir dire transcript will remain
under seal, with the limited expectations requested herein, this Court need not be concerned
about the risks that may be posed by full disclosure of the same, and therefore does not need to
consider the risks of widespread disclosure in deciding the instant motion.
While the court was right to seal the Jury Questionnaire and voir dire transcript from the
public given the circumstances of the trial, the circumstances have changes since that time. Now
that the Jury Questionnaire of Juror 50 specifically is at issue, Juror 50’s attorney should be
granted access to the document under seal. The privacy concerns that favor limiting access to the
Jury Questionnaire and voir dire transcript by others do not apply to Juror 50 himself, given his
unique involvement and personal role in the inquiry directed by the order of this Court. As such,
the balancing of the relevant factors strongly supports granting Juror 50 access to his own Jury
Questionnaire and the transcript of his voir dire testimony, under seal, especially in light of the
unique facts and circumstance presented by this matter.
IV. CONCLUSION
For the above stated reasons, Juror 50 respectfully requests the Court release a copy of
the Jury Questionnaire and the transcript of Juror 50’s voir dire testimony to the Prosecution,
defense counsel, and the attorney for Juror 50, under seal, and that the Court grant his motion to
intervene.
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DOJ-OGR-00008990
Extracted Information
Document Details
| Filename | DOJ-OGR-00008990.jpg |
| File Size | 672.3 KB |
| OCR Confidence | 95.2% |
| Has Readable Text | Yes |
| Text Length | 1,990 characters |
| Indexed | 2026-02-03 17:40:19.059590 |