Document 608

Case 1:20-cr-00330-PAE Document 608 Filed 02/24/22 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------------X THE UNITED STATES OF AMERICA - against - GHISLAINE MAXWELL Defendant. --------------------------------------------------------X NOTICE OF MOTION TO INTERVENE AND FOR THE RELEASE OF DOCUMENTS UNDER SEAL Case No.: 20-CR-330 (AJN) PLEASE TAKE NOTICE that Applicant in Intervention, Juror 50 ("Applicant"), hereby moves the Court to grant him the right to intervene in the above-captioned case for the purpose of defending his significant and threatened privacy interests regarding his experience(s) as a survivor of past sexual assault. On January 5, 2022, this Court ordered the parties to submit briefs in which each shall "address whether an inquiry of some kind is permitted and/or required, and, if so, the nature of such an inquiry". Order. 1. Jan. 5, 2022. 20-CR-330. The Court further ordered that "If counsel for the juror wishes to be heard on the issue of the appropriateness of an inquiry, briefing by the juror's counsel may be filed by January 26, 2022." Order. 1. Jan. 5, 2022. 20-CR-330. As this Court has already set forth a briefing schedule in this matter, Applicant agrees to follow the briefing schedule as directed by the Court, should the instant motion allowing him to intervene be granted. As another preliminary matter, Juror 50 seeks to have copies of his Jury Questionnaire and the transcript of his voir dire released under seal to his counsel, the Prosecution, and Defense 1 DOJ-OGR-00008978 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 608 Filed 02/24/22 Page 2 of 2 Counsel so that he may make a knowing determination as to whether or not he "wishes to be heard on the issue of the appropriateness of an inquiry, briefing by the juror's counsel may be filed by January 26, 2022". Order. 1. Jan. 5, 2022. 20-CR-330. Applicant files contemporaneously herewith a Memorandum in Support of Motion to Intervene, by Todd A. Spodek, Esq., dated January 10, 2022. WHEREFORE, Applicant in Intervention respectfully request this Court grant his Motion to Intervene in this matter as of right, or in the alternative, for permissive intervention, and that the Court grant his application in all other respects. Dated: New York, New York January 10, 2022 Respectfully Submitted, /S/ Todd Spodek, Esq. Spodek Law Group P.C. 85 Broad Street, 17th Floor New York, New York 10004 Tel: (347) 292-8633 / (212) 300-5196 Fax: (212) 300-6371 ts@spodeklawgroup.com Attorney for Proposed Intervenor 2 DOJ-OGR-00008979