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Case 1:20-cr-00330-PAE Document613 _ Filed 02/24/22 Page 38 of 66 defense based on having suffered domestic violence at the hands of the victim, that a juror living in similarly abusive circumstances at the time of trial, and who gave dishonest answers regarding that subject at voir dire, was impliedly biased); United States v. Eubanks, 591 F.2d 513, 517 (9th Cir. 1979) (per curiam) (implying bias where, in a trial for participation in a heroin distribution conspiracy, a juror failed to disclose at voir dire that he had two sons who were serving long prison sentences for heroin-related crimes). Second, courts imply bias when “repeated lies in voir dire imply that the juror concealed material facts in order to secure a spot on the particular jury.” Daugerdas, 867 F. Supp. 2d at 472 (quotation omitted). “A juror... who lies materially and repeatedly in response to legitimate inquiries about her background introduces destructive uncertainties into the process.” Dyer, 151 F.3d at 983. Under both theories, Juror No. 50 was impliedly biased. First, bias should be implied because this is a case in which “there are similarities between the personal experiences of the juror and the issues being litigated.’” Daugerdas, 867 F. Supp. 2d at 472. “When a juror has life experiences that correspond with evidence presented during the trial, that congruence raises obvious concerns about the juror’s possible bias.” Sampson v. United States, 724 F.3d 150, 167 (1st Cir. 2013) (citing Torres, 128 F.3d at 47-48; Burton, 948 F.2d at 1158-59). “In such a situation, the juror may have enormous difficulty separating her own life experiences from evidence in the case.” /d. The First Circuit has commented, for example, that “it would be natural for a juror who had been 31 DOJ-OGR-00009039