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Case 1:20-cr-00330-PAE Document615_ Filed 02/24/22 Page 24 of 49 that must be followed,” but a standard question, approved by the Second Circuit, is: “If you are selected to sit on this case, will you be able to render a verdict solely on the evidence presented at the trial and in the context of the law as I will give it to you in my instructions, disregarding any other ideas, notions, or beliefs about the law that you may have encountered in reaching your verdict?” Id. at 43-44. With respect to Juror 50, the defendant has presented no evidence to support a claim of actual bias. In a public interview, Juror 50 stated that he “went into the trial firmly believing that Maxwell was ‘innocent until proven guilty’ and viewing the victims with a skeptical eye” and that his own experience of sexual abuse “did not affect his ability to view Maxwell as innocent until proven guilty.” (Gov’t Ex. B at 2, 8). These statements are corroborated by the apparent care with which the jury approached its deliberations—asking for testimony and other evidence in numerous questions submitted over the course of multiple days of deliberations—and by its return of a split verdict, in which it acquitted the defendant on one count. See United States v. Aiello, 771 F.2d 621, 631 (2d Cir. 1985) (citing apparent care with which jury approached deliberations and split verdict as evidence of impartiality); Greer, 285 F.3d at 174 (citing split verdict as evidence of impartiality). And Juror 50’s public statements are further corroborated by his answers during voir dire, during which he unequivocally stated that he would be able to follow the law as instructed by the Court, that he would decide the case based on the facts and evidence, or lack of evidence, presented in court, and that, other than what he had been asked, there was no reason to think he could not be fair and impartial. See Nov. 16, 2021 Tr. at 128, 130, 134. While the defendant has not argued for a finding of actual bias (Def. Mem. at 38-39), she at times alludes to the argument. For example, the defendant makes much of the fact that Juror 50 called the defendant a “predator,” said the verdict was for “all the victims,” and commented on a 22 DOJ-OGR-00009143