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Case 1:20-cr-00330-PAE Document620_ Filed 02/25/22 Page13 of 21 content of deliberations” but instead to demonstrate that the second juror made a false statement during voir dire, like Juror 50 allegedly did. Maxwell Br. at 50. But this reading of Rule 606 has been squarely rejected by the Supreme Court, which held that the “plain meaning” of this language is that “Rule 606(b) applies to juror testimony during a proceeding in which a party seeks to secure a new trial on the ground that a juror lied during voir dire.” Warger v. Shauers, 574 U.S. 40, 44 (2014). The Defendant’s one-sentence attempt to dismiss Warger because it involved a civil rather than a criminal case is unavailing. Maxwell Reply at 23 n.11. It is the same rule of evidence in issue, and the principles enunciated by the Supreme Court apply here with equal force. The Defendant may also be suggesting in this argument that Rule 606 does not bar Juror 50’s statements because they concern “extraneous prejudicial information,” which is an enumerated exception to the rule. See Fed. R. Evid. 606(b)(2)(A). To the extent that argument is raised, it is meritless. Information is “extraneous” when it is “external to the jury’”—that is, “publicity and information related specifically to the case the jurors are meant to decide,” rather than “the general body of experiences that jurors are understood to bring with them to the jury room.” Warger, 574 U.S. at 51 (cleaned up). So, for example, the Supreme Court has held that a foreperson’s undisclosed experience with a car accident is not extraneous information, even in a motor-vehicle lawsuit where that failure to disclose could have supported a for-cause strike. Id. at 42-43. The same is true here, as the second juror’s alleged undisclosed experience “did not provide either [the juror] or the rest of the jury with any specific knowledge regarding” this particular case. /d. at 51-52. Rather, as this Court instructed, jurors are expected to bring their “reason, experience, and common sense” to bear in evaluating witnesses’ credibility and the 13 DOJ-OGR-00009554