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Case 1:20-cr-00330-PAE Document 645 Filed 03/11/22 Page 28 of 50 28 M3 8TMAX1 1 approached the questionnaire process, whether he took the 2 Court's instructions seriously. We would just propose asking 3 parallel questions about the questions he was asked in person, 4 in particular because the juror was asked during voir dire 5 similar questions about questions of bias for or against the 6 government, impartiality. And so to clarify the record, 7 whether he took answering those questions in person seriously 8 and answered truthfully. y) MS. STERNHEIM: Could we have a moment? 10 THE COURT: You may. 11 (Pause) 12 MR. EVERDELL: Your Honor, I think there was several 13 areas of follow-up here that are warranted. 14 First, the juror made some reference to his healing 15 process. couldn't quite understand what he said at the time, 16 something about how he views himself as a victim or not as a 17 victim of a crime. I think we need to understand his healing 18 process and what he has gone through, because that affects his 19 ability to be an impartial juror in a case involving sexual 20 abuse. Is this something that he still is seeking treatment 21 for? Is this something he is still thinking? How he deals 22 with the healing process and how he thinks about himself as a 23 victim affects how he views the victim witnesses in this case, 24 and I think there ought to be more questions about that. 25 THE COURT: What's the proposed question? SOUTHERN DISTRICT REPORTERS, P.C. (212%) 805-0220 DOJ-OGR-00010243