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Case 1:20-cr-00330-PAE Document 609 Filed 02/24/22 Page 4 of 13

I. PRELIMINARY STATEMENT

Juror 50 respectfully moves this Court and requests an Order granting him the right to intervene in this action, under the Court’s inherent authority, in order to protect his compelling privacy interests and potential criminal liability, both of which are implicated by this Court’s prior order that his conduct during his service as a member of the jury be potentially subject to an investigation to determine the existence of possible juror misconduct.

Juror 50 seeks to intervene at this time in order to protect his privacy rights and his right to avoid self-incrimination, and to further ensure that he will not be prejudiced by any investigation ordered by this Court, should any subsequent action be brought against him as a result of such investigation. First and foremost, obtaining access to the questionnaire Juror 50 completed as part of the selection process for jury service (hereafter the “Jury Questionnaire”) and the transcript of his testimony during voir dire are critical to Juror 50’s ability to determine if he “wishes to be heard on the issue of the appropriateness of an inquiry” by filing a brief. Order at 1. Jan. 5, 2022. 20-CR-330. In order to achieve appropriate access to such documents and records, Juror 50 must be granted leave to Intervene in this action, and thereby given a fair opportunity to brief this Court as to why he should be heard, if indeed he determines that to be necessary.

It is respectfully submitted that, in order to ensure the integrity of the process, the Jury Questionnaire and the transcript of Juror 50’s voir dire should be released, under seal, to Juror 50’s attorney, the Prosecution and Defense Counsel.

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