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Case 1:20-cr-00330-PAE Document 415 Filed 11/04/21 Page3of3 Page 3 of the names and occupations of prospective jurors no more than five days before trial. (Dkt. No. 407, Def. Ex. A). In United States v. Daugerdas, 450 prospective jurors completed a basic hardship questionnaire; the court excused a number of prospective jurors who had claimed hardships on their questionnaires; the court conducted three-day voir dire; the parties exercised peremptory challenges; and trial commenced. 867 F. Supp. 2d 445, 449-51 (S.D.N.Y. 2012). Through the jury selection process, one juror “lied extensively during voir dire and concealed important information about her background.” /d. at 451. That one juror “lied extensively” during voir dire in Daugerdas does not provide a basis for the relief sought here. Neither Kessler nor Daugerdas stands for the proposition that a defendant has a constitutional right to conduct outside research on jurors, much less that a certain amount of time is required to do so. The Court has indicated that it would ensure a fair jury is selected, and the Court has carefully crafted a juror questionnaire and voir dire process with input from the parties on the questions asked of prospective jurors. This process will ensure that a fair jury is empaneled. The defendant’s motion for reconsideration should be denied. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: ___s/ Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (By ECF) DOJ-OGR-00006174