COMMONWEALTH OF MASSACHUSETTS
NORFOLK, SS. SUPERIOR COURT
NO. 2282-CR-00117
)
COMMONWEALTH OF)
MASSACHUSETTS, )
Plaintiff )
)
v. )
)
KAREN READ, )
Defendant )
ee)
SECOND SUPPLEMENTAL AFFIDAVIT BY ALAN JACKSON IN
‘SUPPORT OF KAREN READ’S MOTION TO DISMISS
I, Alan Jackson, declare:
1, Lama partner at the Los Angeles law firm of Werksman Jackson & Quinn
LLP, and I have been licensed to practice law since 1994. I am counsel for
Karen Read (Docket No. 2282CRO117), appearing on her behalf in the
Commonwealth of Massachusetts pro hac vice.
. On Wednesday, July 17, 2024, I was contacted by “Juror EB” (true name and
identity withheld to maintain anonymity). Based on my conversation with
Juror E and that juror’s physical description of himself/herself, where that
Juror was seated, and that juror’s name and occupation, which was also
disclosed during the voir dire process, I was able to positively identify Juror
E as a seated deliberating juror in the trial of this matter.
. Juror E stated that he/she decided to contact me to provide information about
the results of the jury’s decision-making following deliberations.
. Juror E explained that the jury was “unanimous on 1 and 3” that Karen Read
was NOT GUILTY of those charges.
5. Juror E went on to state that the only count on which the jury was
deadlocked was in relation to the “lower charges” on Count 2. I took that to
mean the lesser included offenses associated with Count 2.
xv
x6. Juror E indicated that he/she was happy to provide such information but
wished to remain publicly anonymous.
‘The foregoing is true and correct to the best of my knowledge and belief,
under penalty of perjury under the laws of the United States and the State of
California and the Commonwealth of Massachusetts.
Executed this date of July 18, 2024, at Los Angeles, California.
/S/ Alan Jackson
ALAN J. JACKSON,