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Case 1:20-cr-00330-PAE Document613 _ Filed 02/24/22 Page 52 of 66 basis for a cause challenge or a peremptory challenge. Juror No. 50’s false answers to both questions deprived the Court of any basis for any meaningful inquiry on a topic bearing directly on his ability to serve impartially and the basis for a cause challenge. Jj . _ an Truthful answers from Juror No. 50 would have led the Court and the parties to probe much more deeply into his biases and prejudices, both known and unknown.'’ Had that happened, the record shows that he would have been removed as a potential juror. ‘6 Juror No. 50 continues his media exploits despite being the subject of this Motion and represented by counsel. On January 18, 2022, he appeared in a documentary produced by ITV. See https://www.youtube.com/watch?v=SvnwRuDfrdM at timestamps 01:53, 02:32, 04:10, 05:10, 34:36, 38:41, 39:15. '’ This follow-up questioning would not have been a mere formality. DOJ-OGR-00009053