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Case 1:20-cr-00330-PAE Document615_ Filed 02/24/22 Page 37 of 49 The defendant also argues that the Court and the parties would have “probed” Juror 50 about whether he was able to “set aside his own traumatic experience” when evaluating whether the Government met its burden of proof. (Def. Mem. at 44). Juror 50 confirmed both in writing and during oral voir dire that he could “[a]bsolutely” “decide the case based on the facts and evidence, or lack of evidence, [] presented in court.” Nov. 16, 2021 Tr. at 130:12-16; see id. at 131:1-7 (stating that he had “[n]o doubt” that he “could decide the case based on the facts and evidence, or lack of evidence, here presented in court”); see also Def. Ex. 1, Questions 13 & 41. There is no need for any further inquiry on this subject, beyond perhaps reaffirming that Juror 50 was truthful when he stated that he could decide the case based on the facts and evidence presented in court. Finally, the defendant claims that the Court and the parties would have specifically inquired as to whether Juror 50 was able to fairly evaluate Dr. Loftus’s testimony and impartially assess the defendant’s “defense that her accusers’ memories were unreliable and tainted by money and manipulation.” (Def. Mem. at 44). This claim is belied by the voir dire record. The Court did not ask jurors who answered Question 48 in the affirmative such follow up questions, and rightly so. The purpose of voir dire is not to educate prospective jurors on the defense theories of the case or to determine if prospective jurors agree with such theories or would credit specific, as-yet-uncalled witnesses. Instead, the purpose of voir dire is to “screen individuals who are unable to sit in a fair and impartial manner.” United States v. Pirk, 1S Cr. 142 (EAW), 2018 WL 1027441, at *4 (W.D.N.Y. Feb. 21, 2018); see also United States v. Barnes, 604 F.2d 121, 138 (2d Cir. 1979) (“[T]he purpose of the voir dire is to ascertain disqualifications, not to afford individual analysis in depth to permit a party to choose a jury that fits into some mold that he believes appropriate for his case.” (quotation marks and citation omitted)). Accordingly, it is clear that the Court would 35 DOJ-OGR-00009156