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Case 1:20-cr-00330-PAE Document613_ Filed 02/24/22 Page 9 of 66 role in this process, and it depends on potential jurors to truthfully answer material questions put to them by the Court and the parties. That did not happen here. Juror No. 50 did not truthfully respond to perhaps the most important question put to potential jurors about their personal experiences — a question that pertained directly to the core allegations against Ms. Maxwell: Whether they had been a victim of sexual assault or abuse. Juror No. 50’s false answer undermined voir dire, resulted in a jury that was not fair and impartial, and deprived Ms. Maxwell of her constitutional right to trial by jury. This Court should vacate the judgment and order a new trial. Factual Background I. Jury Selection A. The jury questionnaire This Court summoned about seven hundred potential jurors, providing each of them with a 22-page questionnaire containing 50 questions. Groups of 100 or more jurors were gathered in the courthouse in morning and afternoon sessions over the course of three days. They were given as much time as needed to complete the questionnaires. Potential jurors signed the questionnaires and swore to the accuracy of their responses under penalty of perjury. The questionnaire’s purpose was to provide the parties with information about potential jurors and to discern whether any potential juror could not be fair and impartial. The Court assured the parties that any affirmative answers to questions would be the subject of follow up questioning during the oral voir dire. DOJ-OGR-00009010