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Case 1:20-cr-00330-PAE Document 609 Filed 02/24/22 Page 11 of 13

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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