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Case 1:20-cr-00330-PAE Document615_ Filed 02/24/22 Page 20 of 49 The defendant also fails to establish that Juror 50 falsely answered Question 25, when he gave a negative response to the question whether he or relatives or close friends have been the victim of a crime. Juror 50 has not publicly disclosed the particulars of any sexual abuse that he suffered, and thus it is not apparent whether it was in fact a crime. Nor is it apparent that, if the abuse was criminal, Juror 50 deliberately lied when he answered Question 25 in the negative, as lay persons often may not think of themselves as victims of a crime even where lawyers and judges would. See, e.g., Fell, 2014 WL 3697810, at *6-7, *13 (crediting juror’s explanation that she did not disclose past sexual abuse in response to question about whether she had been a victim of a crime because she did not consider the abuse, for which the abuser was never prosecuted, a crime); see also McDonough, 464 U.S. at 555. 18 DOJ-OGR-00009139