I think the attorneys were either in the room with the judge, or were given a transcript of the questions and answers they were asked regarding the JM being asked for autographs, and responding politely, the one time he left through the front doors.
Since the motion states for reason that the court 'refer back to the transcripts of these proceedings for factual basis' - which means they don't want to or can't say - in the motion.
Based on the way it's written, if I understand correctly, she could have said almost anything, even that she's seen the defense attorneys leave through the same doors many occasions, and that could be enough for them to argue this.
My own opinion, is that it's probably a ridiculous reason, and they want #5 off the jury, and will use any reason to get that.