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Case 1:20-cr-00330-PAE Document 648 Filed 03/15/22 Page 12 of 16 his ability to render a verdict based solely on the evidence presented at trial and the Court’s instructions as to the law, and that “[a]bsolutely in no way” would his experience with prior sexual abuse interfere with his ability to assess the credibility of witnesses alleging sexual abuse. (/d. at 25:23-26:10). Juror 50 answered the questions quickly and forthrightly, and his demeanor evinced that he was a fair and serious juror who deeply regretted making an inadvertent error. See Greer, 285 F.3d at 171 (quoting United States v. Torres, 128 F.3d 38, 44 (2d Cir. 1997), for the proposition that a “finding of actual bias is based upon determinations of demeanor and credibility that are peculiarly within a trial judge’s province.”).‘ On this record, it is evident that Juror 50 would not have been struck for cause. Of the 58 individuals who were qualified to serve as jurors, eight individuals disclosed in their written questionnaires that they themselves had been a victim of sexual harassment, sexual abuse, or * Juror 50’s answers about whether he thought his family or friends would learn about his sexual abuse through his press interviews do not undermine his credibility. While the trial participants, who have been attentive to developments in this case for years, quickly learned of Juror 50’s statements, Juror 50 reasonably thought differently about his friends and family. As Juror 50 explained, his family and friends “didn’t even know that this trial was even happening” when he revealed that he had been on the jury through social media—media in which he did not reveal his own experience with abuse. (Mar. 8, 2022 Tr. at 42:15-43:9). Juror 50 therefore expected that “a little article about a juror giving their experience wouldn’t be . . . really in the news at all.” (dd. at 42:21-23). His family and friends appear not to have consumed media about the trial—yjust like many of the actual and prospective jurors in this case, who reported no or almost no exposure to the defendant or Jeffrey Epstein on their questionnaires. (See, e.g., Juror 7; Juror 20; Juror 37; Juror 54; Juror 89; Juror 151). It is even more unlikely that they would learn about his experience with abuse given that Juror 50 did not use his last name, disconnecting his press interviews from his Google search results, and that he gave two of his three interviews to foreign press. (See Dkt. No. 643 at 8-9). And Juror 50 did not think that his interviews would trigger significant public attention and further proceedings in the case because he had attempted to answer the questions honestly and had nothing to hide. (Mar. 8, 2022 Tr. at 22:23-23:5 (“I didn’t think this would happen ... if I lied deliberately I wouldn’t have told a soul. I certainly wouldn’t have put myself in a position . . . this position that I’m in now, potentially any sort of criminal charges, I just wouldn’t have done it. It was an honest mistake ....”)). At worst, Juror 50’s expectations about the consequences of his interviews reflect naivety; they do not reflect deception. 10 DOJ-OGR-00010302