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Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 13 of 66 e Question 47, “No,” Juror No. 50 would not have any difficulty assessing the credibility of alleged victims of sexual assault or abuse just as he would assess the credibility of any other witness. e Finally, and most importantly, Juror No. 50 answered “no” when asked in Question 48 if he had ever been the victim of victim of sexual harassment, sexual abuse, or sexual assault, including actual or attempted sexual assault or other unwanted sexual advance, including by a stranger, acquaintance, supervisor, teacher, or family member. C. Juror No. 50’s voir dire Prior to trial, defense counsel moved the Court to permit limited, attorney- conducted voir dire of potential jurors. Doc. 342. Defense counsel explained that given the nature of the allegations, the stakes involved, and the omnipresent media coverage, attorney-conducted voir dire to supplement the Court’s voir dire was necessary to ensure a fair and impartial jury. /d. at 7-15. Defense counsel pointed specifically to the potential that certain jurors could not be fair if they had been a victim of sexual assault or sexual abuse. /d. at 9-10. The Court declined to permit attorney-conducted voir dire. TR 10/21/2021, p 8. Prior to trial, defense counsel also proposed that the Court individually ask each juror 1n person several questions including "Have you or anyone close to you ever been the victim of a crime?" and "Have you or has anyone close to you ever been the victim of a sexual crime?" Doc. 367-1 at 14. The government objected that the questions were "duplicative of questions included in the proposed voir dire" and should not be asked DOJ-OGR-00009705