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Case 1:20-cr-00330-PAE Document 609 Filed 02/24/22 Page 6 of 13

when questioned about his answers to the Jury Questionnaire; therefore Juror 50 has a
compelling need to be able to separately confirm his recollection—regardless of whether or not
there may exist a lapse in such recollection—and to be fully prepared to explain himself, as may
be necessary, pursuant to an inquiry directed by the order of this Court. Juror 50 further desires
to maintain his privacy and, to the extent possible, avoid having to disclose intimate details of his
experience as the victim of prior sexual assault.

III. ARGUMENT
For the reasons set forth below, the Court should, in its proper exercise of discretion,
allow Juror 50 to intervene in this action and grant release, under seal, of a copy of his Jury
Questionnaire to his attorney, the Prosecution and Defense Counsel.

The relevant precedent from case law makes it abundantly clear that jurors have
compelling and legitimate rights to privacy regarding “intensely personal subjects,” including
prior sexual assaults. Juror 50’s right to privacy is clearly implicated by an inquiry by and before
this Court, as the same relates directly and specifically claims concerning his experience(s) as a
survivor of past sexual abuse and discussions he may have had with other jurors, in which he is
alleged to have detailed his history as a victim of prior sexual assault. These factors are
heightened by the intense media scrutiny surrounding the instant case and the already significant
press coverage of Juror 50 himself, including the statements that he has made to the media about
his jury service.

Judge Nathan specifically invited Juror 50 to address the “appropriateness of an inquiry”
into his conduct as a juror and affect that his personal history may have had on juror
deliberations and the verdict rendered in this matter. Order at 1. Jan. 5, 2022. 20-CR-
330.Therefore, by allowing Juror 50 to intervene in this action, this Court can ensure that Juror

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