Case 1:20-cr-00330-PAE Document582 Filed 01/25/22 Page1of4 Li Davis Wright 1301 K Street NW J Tremaine LLP Washington, D.C. 20005-3317 Nathan Siegel 202.973.4237 tel [email protected] January 25, 2022 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square, Room 2102 New York, NY 10007 Re: USA v. Maxwell, No. 1:20-cr-00330-AJN Dear Judge Nathan, I write on behalf of American Broadcasting Companies, Inc. (“ABC News”) and NBCUniversal News Group (“NBC News”) to join in the requests of The Miami Herald (Dkt. No. 581) and The New York Times to oppose the sealing of the motion for a new trial and supporting exhibits filed by the Defendant (Dkt. No. 578), for all the reasons set forth in those requests. ABC News and NBC News further respectfully request that Juror 50’s_ motion to intervene, which according to this Court’s prior orders (Dkt. Nos. 575 & 576) was e-mailed to the Court and placed under temporary seal, now be unsealed. Like the Defendant’s Motion for a New Trial, Juror 50’s motion is a “judicial document” to which the presumption of access under both the common law and the First Amendment applies because Juror 50’s motion has been, and continues to be, highly “relevant to the performance of the judicial function and useful in the judicial process.” U.S. v. Amadeo, 44 F. 3d 141, 145 (2d Cir. 1995) (“Amodeo I”). DWT.COM Anchorage | Bellevue | Los Angeles | New York Portland | San Francisco | Seattle | Washington, D.C. 4863-7911-5787v.1 0019918-000033 DOJ-OGR-00008829