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Case 22-1426, Document 87, 07/27/2023, 3548202, Page28 of 35 D. Juror 50’s Actual, Implied, and Inferable Bias Was Established. Maxwell does not seek a per se rule of exclusion of victims of child abuse in sex trafficking cases, although admittedly, it would be difficult to imagine how such a traumatic experience could fail to give rise to inferable bias. Certain life experiences create permanent biases. Nevertheless, it is this juror in this situation that the law would properly “cautiously incapacitate” because persons in such a situation would naturally feel prejudice. In his post-verdict interviews, Juror 50 admitted as much when he described how he identified with the Government witnesses through the lens of his own experience of child sexual abuse; convinced other jurors to credit the testimony of Government witnesses and discredit defense witnesses precisely because of his unique insight about memory for child sexual assault; and bonded so profoundly with the Government witnesses that he felt compelled to contact one after trial and to give interviews about his own experience. Suffice to say, this was not an example of an impartial juror using his “life experiences” in the performance of his civic duty, contrary to the Court’s view. A352. Juror 50 had no such relationships to the parties, counsel, or the very crime itself. But his omissions during voir dire presented the sort of "extreme situation" that would qualify for presumptive bias. Torres at 46. The average person, victimized by sexual abuse, would be biased when he speaks about his healing 22 DOJ-OGR-00021770