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Case 1:20-cr-00330-PAE Document636 Filed 03/01/22 Page 15 of 22 The Honorable Alison J. Nathan March 1, 2022 Page 15 asked, at the time of jury selection, whether he could still be fair and impartial juror despite his experience with childhood sexual abuse. Similarly, it serves no purpose to ask Juror 50, after the fact, whether his experience with childhood sexual abuse affected his ability to be a fair and impartial juror during the deliberations. Both questions will elicit only self-serving answers. The Court should, instead, ask Juror 50 questions that are designed to elicit the impact that the sexual abuse had on Juror 50 and his ability to impartially assess evidence of a case involving sexual abuse. 1. How has the sexual abuse you experienced as a child affected your life? a. Did it affect how you interact with people? How? b. Did it affect your ability to trust people? How? c. Did it affect your personal relationships? How? 2. Have you ever been involved in victims’ rights groups or victim advocacy? a. Do you support victims’ rights or victim advocacy groups? b. Are you a member of any of these groups? c. Do you donate your time to these groups? d. Do you donate money to these groups? e. Have you ever attended rallies or protests in support of victims’ rights? 3. Did you seek mental health counseling to address the abuse you experienced? a. You have spoken publicly about your own therapy in your social media posts? b. How long have you been in therapy? c. Have you used your therapy to address your feelings about the abuse? 2100689.3 DOJ-OGR-00009652