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Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 49 of 66 several different news outlets (some of which he was likely paid for) '*, and he sat for an interview as part of an hour-long “documentary” called “Ghislaine, Prince Andrew and the Paedophile,” which aired on the British channel ITV. He has engaged on Twitter with the journalist who wrote about him, and he has communicated directly with Annie Farmer. See Ashfar, 196 A.3d at 95-96 (relying on juror’s post-trial conduct as a basis for concluding juror was biased and new trial was required because juror falsely answered material question during voir dire). Juror No. 50’s publicity tour appears to have stopped (at least temporarily) only because the government publicly filed a letter asking this Court to inquire into Juror No. 50’s truthfulness and suggesting that he needed a lawyer. The clear message from the government to Juror No. 50 was to stop talking. !° ‘4 Tt is common for the British press to pay for crime victims’ stories. See, e.g, https://www.mirror.co.uk/sell-my-story/; https://trianglenews.co.uk/sell-my-story-to-the- daily-mail/; https://www.dailymail.co.uk/home/contactus/index.html 'S Juror No. 50 was clearly enjoying his fifteen minutes of fame in early January 2022, giving multiple interviews in which he congratulated himself as the person who persuaded the other jurors to adopt his biased view of the evidence and to vote to convict Ms. Maxwell. The government recognized that Juror No. 50 had dug a very deep hole—a hole that looked to be getting deeper. Without conferring as to either the submission of the letter or any redactions, the government publicly filed Docket No. 568. This letter communicated to Juror No. 50, and the media, that Juror No. 50 had done something wrong, that his conduct would be subject to scrutiny, and that the conduct was serious enough to warrant appointment of a lawyer, free of charge if necessary. Had Ms. Maxwell been asked, she would have objected to the public filing of this letter, which caused Juror No. 50 to delete his social media accounts and alerted Juror No. 50 that he needed to stop giving media presentations and to work on his story. The government knows how to file a letter under seal, and this Court’s protocol throughout this case has been for the parties to file letters or pleadings under restriction with a conferral and briefing as to what portion of the document should be redacted. The 42 DOJ-OGR- 00009741