Motion for New Trial for Dishonest Juror

Here is the link to the motion for a new trial in the Paul Daugerdas case.  Daugerdas and his co-defendants were convicted of tax fraud for creating illegal tax shelters last year.  The defendants are now requesting a new trial because one of the jurors (#1) who decided the case lied repeatedly during voir dire e.g., she failed to disclose that she was a disbarred attorney with an outstanding warrant.  In addition, this juror, at the conclusion of the case, sent the prosecution a congratulatory letter.  The defendants have a real chance of succeeding on their motion.  The one potential stumbling block concerns whether counsel for defendants was aware or should have been aware of Juror #1's true identity before the jury returned a verdict.