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This legal document, filed by the Reporters Committee for Freedom of the Press, argues against a defendant's request to seal the juror questionnaire and voir dire process from the public. Citing multiple legal precedents, the filing asserts that there is a strong presumption of openness and the defense has failed to meet the 'heavy burden' of proof required to justify such secrecy. The document urges the court to deny the defendant's request and order the materials to be filed on the public docket.