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Case 1:20-cr-00330-PAE Document 612 Filed 02/24/22 Page1of5 Haddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca oO 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com joagliuca@hmflaw.com HADDON MORGAN FOREMAN January 13, 2022 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: — United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, Ms. Maxwell requests that the “Memorandum of Law in Support of Motion to Intervene and for Release of Sealed Jury Questionnaire and Transcript, on Behalf of Proposed Intervenor, Juror 50” and its companion Motion remain under seal, at least until a resolution of Ms. Maxwell’s forthcoming motion for new trial based on this Juror’s failure to answer truthfully during jury selection. Juror 50’s Motion and accompanying Memorandum are an attempt to obtain discovery by a non-party to this criminal case, made by someone who lacks standing to participate in this prosecution. Accordingly, these pleadings are not “judicial documents” and are afforded no presumption of public access. Juror 50 first seeks to intervene suggesting that “it is indisputable that precedent supports intervention by interested third parties in criminal matters....” Memo. at 8. Au contraire, “the long line of precedent hold[s] that a non-party lacks a judicially cognizable interest in a defendant's prosecution.” United States v. Stoerr, 695 F.3d 271, 278 (3d Cir. 2012). Juror 50 is not a party here and there is no legal basis for Juror 50 to intervene in this DOJ-OGR- 00008997