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Case 1:20-cr-00330-PAE Document 342 Filed 10/13/21 Page14of17 for the court's evaluation, ‘merely going through the form of obtaining jurors’ assurances of impartiality is insufficient [to test that impartiality]”) (citation omitted). Because it is extremely likely that prospective jurors have been exposed to potentially prejudicial pretrial publicity, specific, individual voir dire is required. Davis, 583 F.2d at 196-97. To increase the likelihood that any hidden prejudices of the jurors will be uncovered, to accomplish the goal of exercising sensitive and intelligent peremptory challenges, and to ensure that a fair and impartial jury is empaneled in this case, counsel should be given an opportunity to individually examine prospective jurors. Individual sequestered voir dire conducted jointly by counsel and the Court has a variety of benefits. It invites a conversation rather than posing an interrogation. It eliminates the pressure on jurors to provide socially desirable or acceptable answers in a group setting, reduces conformity pressures that can diminish candor, and removes the risk of other jurors being influenced by statements made during group voir dire that enable them to either stay on the jury or be removed for cause. It increases juror comfort, minimizes the anxiety of public speaking, encourages candor, and promotes honesty. Furthermore, questioning conducted exclusively by the Court further hampers the ability to uncover important information about jurors because it places jurors in a subordinate position heightening their reluctance to be candid. Attorney-conducted questioning bridges the status gap between the humble layperson and the honorable judicial officer exalted high above the venire. Research indicates that expansive voir dire yields greater revelations of juror bias;? and in-depth attorney-conducted voir dire combined with individual sequestered voir dire elicits greater 3 See, e.g., Moran, Cutler & Loftus. Jury Selection in Major Controlled Substance Trials: The Need for Extended Voir Dire, 3 Forensics Reports 331(1990). 13 DOJ-OGR-00005219