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Case 1:20-cr-00330-PAE Document 648 Filed 03/15/22 Page11of16 At the hearing, the Court questioned Juror 50 to determine whether, if he had answered accurately, it would have granted a hypothetical strike for cause. The record before this Court makes clear that Juror 50 would not have been struck for cause. The Court began by asking Juror 50 what his answers would have been to Questions 25(a), 48(b), and 49(b) of the questionnaire, which asked whether his experience would have prevented him from being a fair and impartial juror in this case. Juror 50 repeatedly indicated that he would have answered those questions in the negative. For example, when asked how he would have answered Question 48(b)—which asked if his prior experience with sexual abuse would affect his ability to serve fairly and impartially as a juror in the case—Juror 50 responded that his answer “would have been no, because it did not affect [his] ability to be fair and impartial at all.” (Mar. 8, 2022 Tr. at 9:15-16; see also id. at 10:23-24 (“[An accurate answer to Question 25(a)] would have been no. I was definitely able to set aside everything and be fair and impartial.”)). Juror 50 unequivocally stated, “In no case [would my experience affect my ability to serve fairly and impartially]. It would not affect me.” (/d. at 13:15). After asking Juror 50 how he would have answered those follow-up questions on the questionnaire, the Court took Juror 50 “back in time” to November 16, 2021, the day of voir dire, and asked Juror 50 the additional questions it would have asked that day had Juror 50 accurately filled out Questions 25, 48, and 49 of the questionnaire. (/d. at 24:18-27:17). In response to the Court’s question as to whether his history of sexual abuse would affect his ability to be a fair and impartial juror, Juror 50 testified that his prior experience with sexual abuse “would not affect [his ability to be a fair and impartial juror] in any way” and that he would not be “thinking about [his] own experience in a way that would prevent [him] from being fair or impartial.” (/d. at 25:17-22, 27:4-6). Juror 50 explained that there was nothing about his experience that would have affected DOJ-OGR-00010301