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Case 22-1426, Document 59, 02/28/2023, 3475902, Page82 of 113 for a challenge for cause’” Daugerdas, 867 F. Supp. 2d at 470. Challenges for cause can be based on implied bias, inferred bias, or actual bias. United States v. Torres, 128 F.3d 38, 43 (2d Cir. 1997). Clearly, had Juror No. 50 disclosed his “traumatic” victimization, his truthful answers to follow-up questions would have provided a valid basis for a challenge for cause because of the similarity of Juror 50’s sexual abuse experience to the evidence in the case and the materiality of the nondisclosures. In determining whether Juror No. 50 was biased, and whether a hypothetical challenge for cause would have been granted, a court should consider several factors, including (1) the similarity between Juror No. 50’s past experience and the experiences of the witnesses who testified at trial, as well as (2) the severity of the juror’s dishonesty, and (3) the juror’s motives for lying. See, Sampson v. United States, 724 F.3d 150, 166 (1* Cir. 2013). Here, Juror 50’s undisclosed experience was strikingly similar to the experiences described by the witnesses at trial. Juror 50 was a victim of childhood sexual abuse; was abused as a minor on multiple occasions over the course of several years; was abused by someone he knew and trusted and another person; and delayed disclosing the abuse for years. A267-268. Juror 50’s experience is more troubling because it directly bore upon Maxwell’s central trial defense 1.e., that the testimony of the complaining witnesses was unreliable because it 67 DOJ-OGR-00021129