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Case 1:20-cr-00330-PAE Document636 Filed 03/01/22 Page 18 of 22 The Honorable Alison J. Nathan March 1, 2022 Page 18 8. Do you agree with the following statement: “Based on my own experience and without knowing the particular facts of any case, if someone claims that they were abused, it is more likely that I will believe they are telling the truth”? 9. Do you believe that people who make allegations of being sexually abused as a child are usually telling the truth? 10. Do you believe that victims would not go through the stress of testifying at trial about the sexual abuse they suffered as a child unless they were telling the truth? D. Questions to Elicit Whether Juror 50’s Responses to Questions 48 and 25 of the Jury Questionnaire Were Deliberately or Intentionally False The Court did not resolve whether the standard for a new trial requires the prospective juror to make a deliberate false statement on the jury questionnaire or whether an inadvertent misstatement is sufficient as long as a correct response would have provided a valid basis for a challenge for cause. See 2/24/2022 Op. & Order at 4n.3. The defense and the amici believe that that a deliberate misstatement is not required. Nevertheless, because this issue has not been resolved, the Court should ask additional questions to elicit whether Juror 50’s responses to Questions 48 and 25 were deliberately false. That includes questions to establish when he first spoke to the press, whether he contacted the press himself, whether he got paid for his interviews, and what his intentions were about serving on the Maxwell jury. Ms. Maxwell submits that whether Juror 50 received payment for interviews after the trial is probative of his intention to not disclose information during voir dire that would have called into question his ability to serve as a fair and impartial juror. As discussed in the Amicus Brief, fame, prestige, and profit are powerful motivators; and the lure has given rise to the so-called 2100689.3 DOJ-OGR-00009655