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Case 1:20-cr-00330-PAE Document 649 _ Filed 03/15/22 Page 2of12 LAW OFFICES OF BOBBI C. STERNHEIA\ Maxwell, so he attempted to give innocuous explanations for his false questionnaire responses and his decision to “tell his story” to the international press following trial. In fact, Juror 50’s responses only further revealed his bias. In the end, what was evident before the Hearing is even more clear after the Hearing — had Juror 50 given truthful answers on the questionnaire, his biases and sympathies would have been fully explored and he would have been challenged, and excluded, for cause. Instead, Juror 50’s false responses to the most critical questions on the questionnaire undermined voir dire and deprived Ms. Maxwell of her constitutional right to a trial by a fair and impartial jury. 1. The Hearing Testimony Established that Juror 50 Falsely Answered Three Critical Questions on the Jury Questionnaire. There can be no dispute that Juror 50’s testimony established conclusively that he falsely answered three separate questions on the jury questionnaire — Questions 48, 25, and 49. It is no coincidence that Juror 50 gave false answers to these questions. These were the questions that, had he answered truthfully, would have revealed his prior sexual abuse. Question 48 asked “Have you or a friend or family member ever been the victim of sexual harassment, sexual abuse, or sexual assault?” (Court Exhibit #1 at 24). Juror 50 had answered “No.” (/d.). Juror 50 admitted that this was not an accurate answer and that the truthful answer was “Yes (self)” because he had, in fact, been sexually abused as a child by his stepbrother and his friend. (Tr. 7- 8). Question 25 asked “Have you, or any of your relatives or close friends, ever been a victim of acrime?” (Court Exhibit #1 at 13). Juror 50 had answered “No.” (/d.). Juror 50 admitted that this was not an accurate answer and that the truthful answer was “Yes (self) because of the same childhood sexual abuse. (Tr. 9-10). Finally, in light of Juror 50’s statement that he had been sexually abused by his stepbrother, the Court confronted Juror 50 about his answer to DOJ-OGR- 00010308