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Case 1:20-cr-00330-PAE Document613_ Filed 02/24/22 Page 51 of 66 I will individually, one-on-one, question[] the jurors, and with the parties present, I feel confident that I can discern any clear dishonesty. This is not just going to be a summary voir dire; it will be probing. . . . Ifa juror’s going to lie and be dishonest, we will smoke that out. TR 10/21/2021, p 25-26. Because Juror No. 50 did not honestly answer these material questions, however, the Court and the defense were not alerted to probe these issues and instead relied on Juror No. 50’s claim that he could be fair and impartial. In hindsight, that claim is not credible. This is not speculation. Rather, based on what Juror No. 50 has said to the media, it’s clear he was not fair and impartial because his personal experiences “prevent[ed] or substantially impair[ed] the performance of his duties as a juror in accordance with his instructions and his oath.” Wainwright, 469 U.S. at 424. If Juror No. 50 had truthfully disclosed that he was a victim of sexual assault and sexual abuse as a child, the Court and parties would have probed, among other things, whether he was able (1) to assess the credibility of alleged sex assault victim like all other witnesses; (2) to fairly evaluate the testimony of Dr. Loftus; (3) to impartially assess Ms. Maxwell’s defense that her accusers’ memories were unreliable and tainted by money and manipulation; and (4) set aside his own traumatic experience when evaluating whether the government met its burden of proof beyond a reasonable doubt. Juror No. 50’s failure to disclose that he was a victim of sexual abuse (Question 48) was further compounded by his failure to disclose that he was merely a victim of a crime (Question 25). Disclosing that he was a crime victim would have invited inquiry by counsel and the Court regarding the nature of the crime and would have provided a 44 DOJ-OGR-00009052