DOJ-OGR-00009000.pdf

Case 1:20-cr-00330-PAE Document 612 Filed 02/24/22 Page 4 of 5 The Honorable Alison J. Nathan January 13, 2022 Page 4 There exists no compelling reason to release Juror 50's pleadings. Any public release of the documents will set off another round of publicity, speculation, and commentary, all of which is prejudicial to the truth finding process and Ms. Maxwell's rights to fair and impartial proceedings. The pleadings filed by Juror 50 have questionable merit, have not been ruled upon, and implicate an ongoing investigation by the parties and the court into juror misconduct. Certainly, at least at this stage of the proceedings, the pleadings are not "judicial documents" and until the issues around Juror 50's motion for intervention and discovery have been resolved they should remain sealed. If the Court believes Juror 50's pleadings merit judicial document status the seal should remain. The pleadings would be afforded the lowest presumption of public access and compelling reasons to maintain the sealed status exist. Juror 50 has demonstrated a lack of reliability and an appetite for publicity. Should the documents be released the sotto voce comments regarding Juror 50's intent, state of mind, and actions will be fodder for the media and may influence the memories of other potential witnesses, including notably the other jurors. Documents regularly remain sealed where public release would "compromise" the interest in the integrity and security of [an] investigation," In re Sealed Search Warrants Issued June 4 & 5, 2008, No. 08-M-208 (DRH), 2008 WL 5667021, at *5 (N.D.N.Y. July 14, 2008). DOJ-OGR-00009000