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Case 1:20-cr-00330-PAE Document 649 _ Filed 03/15/22 Page6of12 LAW OFFICES OF BOBBI C. STERNHEIA\ decided post-trial to reach out to one of the victims in this case, publicly acknowledge his own sexual abuse, and loudly proclaim to the international press that Ms. Maxwell’s guilty verdict was a verdict “for all the victims.” At the Hearing, Juror 50 explained his reasons for doing this: “After sitting on this trial for several weeks and seeing the victims be brave enough to give their story, I felt like if they can do it, then so can I.” (Tr. 24). Juror 50’s testimony shows that the victims’ testimony personally resonated with him in a way that jurors who had not been sexually abused as children would not have felt. It caused him to regard himself as an advocate of the victims rather than a neutral arbiter of the facts. Even if the Court credits Juror 50’s contention (and it should not) that he did not have these emotions at the time of voir dire and only developed them after hearing the witness’ testimony, it still shows that Juror 50 was not capable of “separating [his] own life experiences from the evidence in the case.” Sampson, 724 F.3d at 167; see also Ashfar, 196 A.3d at 94-97 (finding bias for juror who did not disclose his prior sexual abuse, communicated with a female victim of sexual assault, and identified himself as “an advocate for the people”). Moreover, the hearing testimony established that Juror 50’s history of sexual abuse did, in fact, compromise his ability to be fair and impartial. Prior to the Hearing, Juror 50 told the press that he recalled several details of his own sexual abuse and that “some of it can be replayed like a video.” At the Hearing, Juror 50 underscored that his own experience of sexual abuse shaped his beliefs about how victims’ memories of traumatic events work. He stated that he talked to the press about “how I view things and how I can recall memories ... [and] remember things and recall things, like the color of the wall[.]” (Tr. 23). He further stated that his own memories are “why I believe a certain way” about the nature of victims’ memories. (Tr. 22). As set forth in our initial Motion, Juror 50’s beliefs directly contradict Dr. Loftus’ expert testimony DOJ-OGR-00010312