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Case 1:20-cr-00330-PAE Document636 Filed 03/01/22 Page17 of 22 The Honorable Alison J. Nathan March 1, 2022 Page 17 b. You believe that there are parts of your memory of your own abuse that are like a video tape that can be played back? c. Those parts of your memory are frozen and inalterable (like a videotape) and are so vivid that they cannot be altered by the passage of time? d. And you believe that all victims’ memories function this way? e. You believe that victims may not be able to remember all of the details, but they will never forget or misremember the core aspects of the abuse? f. Does that include who participated in the abuse? g. Do you believe it is possible that someone who makes an allegation of child sexual abuse can be mistaken about who abused them? h. You do not credit other people who say that victims may misremember even core details of their abuse? i. You have this belief because that’s how your memory of your own abuse functions? j. That is a belief that you had even before jury selection began? k. And had you been asked about this belief during voir dire, you would have disclosed it? 6. Being a victim of a sexual assault is something you will never forget, is that a fair statement? 7. Asa former victim you are sympathetic to other victims of sexual abuse? 2100689.3 DOJ-OGR-00009654