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Case 1:20-cr-00330-PAE Document620 _ Filed 02/25/22 Page3of21 press outlets about his jury service and requested a hearing be held on the matter. Dkt. No. 568. The letter noted that in the interviews, which were both in print and on video, the juror “described being a victim of sexual abuse” and asserted that he “flew through” the juror questionnaire and did not recall being asked whether he had been a victim of sexual abuse. /d. at 1. The Government indicated in a redacted footnote that it believed the juror to be Juror 50, and a review of his questionnaire showed that he had provided a negative response to a question that asked whether a prospective juror had been a victim of sexual abuse. Jd. at 2 n.2.! Finally, the Government requested that the Court offer court-appointed counsel to the juror in the event a hearing was ordered. A letter from the Defendant followed shortly thereafter also informing the Court about the juror’s interviews. Dkt. No. 569. The Defendant filed a second letter that same day opposing the Government’s request “because based on undisputed, publicly available information, the Court can and should order a new trial without any evidentiary hearing.” Dkt. No. 570.7 The Defendant filed a motion for a new trial on January 19, 2022. The Government opposed the motion on February 2, 2022, and the Defendant filed a reply in support on February 9, 2022. In addition to Juror 50’s post-trial interviews, the Defendant’s motion relies on a New York Times article reporting that “a second juror described in an interview . . . having been ! The Government proposed redacting the footnote because the juror questionnaire was not a public document at that time. Because (for the reasons explained below) the Court now unseals the questionnaire, that redaction is no longer necessary. ? For completeness of the record, the Court notes the following occurred also on January 5, 2022: The Jury Department of the Southern District of New York received a call from Juror 50 asking for guidance because of statements he had given to certain media outlets that were being widely reported on in the press and inquiring whether he needed an attorney. At the Court’s direction, the District Executive returned Juror 50’s call and informed him that the Court was unable to provide any guidance or response to his question. Juror 50 then asked the District Executive if he could access his questionnaire. The District Executive, again at the Court’s direction, informed Juror 50 that the questionnaire was not a public document and could not be provided to him. 3 DOJ-OGR-00009544