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Case 1:20-cr-00330-PAE Document 648 Filed 03/15/22 Page 7 of 16 Juror 50’s testimony about Question 48 was clear and consistent. He made a mistake. His testimony did not evince any intent to deceive or mislead the Court when completing the questionnaire. Rather, it was consistent with his statements in the Daily Mail interview, which was when Juror 50 first learned that the questionnaire may have contained a question that asked about his own sexual abuse history. (/d. at 15:19-22). And it was during the Daily Mail interview, when first confronted with the possibility of having made a mistake, that Juror 50 told the reporter that he “could not remember” the part of the questionnaire asking whether he had experienced sexual abuse, but he “‘was certain that he had answered all questions honestly.” (Dkt. No. 643, Ex. B at 8). Juror 50’s sworn testimony at the hearing echoed his comments to the press when he learned of his error. Juror 50 did not know he “had made a huge mistake,” and upon learning this information during the interview, he was “embarrassed and sort of like shocked and didn’t know that was the full question.” (Mar. 8, 2022 Tr. at 44:19-45:3). Juror 50’s sworn testimony about the mistakes he made when completing the questionnaire—which related to the single topic of the sexual abuse he experienced as a nine-year- old—similarly made clear that he did not intend to inaccurately answer Questions 25 and 49. When the Court inquired at the hearing about Juror 50’s answer to Question 25—which asked whether he or any relatives or close friends had been a victim of a crime—Juror 50 explained that “TlJooking back at [Question 25] now,” his negative answer was incorrect. (/d. at 9:22). He explained that he “wasn’t thinking of [his] sexual abuse as being a victim of a crime because [he] no longer associate[s] being a victim” and that he had been thinking of whether he had been “robbed or mugged or some sort of crime like that” at the time he was completing the questionnaire. (/d. at 10:4-9; see also id. at 16:17-25 (“I do not feel that I am a victim of a crime....”)). Against this backdrop, it is understandable that the questionnaire’s inquiry about DOJ-OGR-00010297

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Filename DOJ-OGR-00010297.jpg
File Size 738.7 KB
OCR Confidence 94.2%
Has Readable Text Yes
Text Length 2,206 characters
Indexed 2026-02-03 17:57:15.941081