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Case 22-1426, Document 87, 07/27/2023, 3548202, Page27 of 35 All three forms of bias must be "grounded in facts developed at voir dire." Torres, 128 F.3d at 47. The bias implied by the juror’s false answers went unexplored. Nieves turned on the court’s failure to explore juror bias related to gangs — a prejudice analogous to the systematic or pervasive bias in the community against accused sex traffickers and those who consort with them. Maxwell, tied to Epstein by media coverage, went to trial against a constant drumbeat of news and allegations concerning child molesters and sex trafficking. Far more pervasive than fear of gang violence was fear and revulsion as to child sex abuse and trafficking of which Epstein, and then Maxwell became the poster child. In the hearing, and despite defense suggested questions, the Court refused to explore Juror 50’s child sexual abuse for bias. To assess a challenge for cause as to this seated juror after trial the court should use the same standards for cause challenges at trial. To do otherwise would appear to shield the verdict rather than the defendant from improper juror bias. As in Nieves, the juror’s omitted information related to a “material issue” that was at trial “the cornerstone of the government’s theory.” There was a strong likelihood that the material issue would skew deliberations considering the strong feelings that sex trafficking of minors engenders. See Nieves; see also Barnes, 604 F.2d at 137- 139. The court deprived Maxwell unfairly of the opportunity post-trial to unearth a pervasive bias relevant to the issue pivotal to the case against her. 21 DOJ-OGR-00021769