It is interesting that the brief only considers the possibility of attacks on jurors coming from supporters of the defendant rather the victim.
That's not true of the brief
itself. It's true of the quoted citation (p. 3), represented as the 'factors most commonly considered' for juror anonymity.
I think that reflects the case law. O'Mara suggested as much in his comments on the federal case law (3/28/13 hearing,
1:20:48). He said that it was mostly organized crime and 'high level' drug cases.
The last paragraph of the brief (p. 4) addresses the other concern.
In fact, and has been previously noted by the Court, the passion that this case has stirred in the community has been expressed in peaceful, non-violent ways.
I recall some press reports about assaults and robberies, in which the perpetrators allegedly said 'This is for Trayvon', or something similar. If there are police reports to go with some of those stories, there may be evidence to dispute the contention, 'previously noted' or not.