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Case 1:20-cr-00330-PAE Document 648 Filed 03/15/22 Page3of16 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ee eee Xx UNITED STATES OF AMERICA -V.- i S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. i RE ESE FE ES x The Government respectfully submits this memorandum in further support of its opposition to the defendant’s motion for a new trial, dated January 19, 2022 (the “Defense Motion”). After the thoughtful and thorough hearing held by this Court, it is crystal clear that the defendant received a fair trial. Juror 50’s sworn testimony at the hearing made evident that he did not deliberately lie in completing the questionnaire, but that he instead made an honest mistake. And in any event, had Juror 50 accurately reported in his questionnaire that he had been a victim of sexual abuse, he would not have been struck for cause. Juror 50 repeatedly explained—yjust as he did during voir dire—that he would be fair and impartial and would decide the case based on the evidence at trial and the law as explained by the Court. Accordingly, under controlling Supreme Court and Second Circuit precedent, the defendant cannot show that Juror 50 harbored any bias against the defendant. Moreover, during voir dire, multiple other potential jurors in this case reported having experienced sexual abuse and were nonetheless qualified as jurors without any objection from the defendant. It was entirely appropriate for Juror 50 to sit on this jury, and nothing about his service as a juror calls into question the integrity of the verdict in this case. DOJ-OGR-00010293