DOJ-OGR-00009720.jpg

Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 28 of 66 C. A second juror admits to disclosing during deliberations that they were a victim of sexual assault During his press tour, Juror No. 50 revealed in interviews that he was not alone in revealing to jurors that he was a victim of sexual assault, describing to reporter that a second juror also disclosed that they were a victim of sexual abuse.* On January 5, the New York Times published an article confirming Juror No. 50’s statement, reporting that “a second juror described in an interview . . . having been sexually abused as a child.” “This juror, who requested anonymity, said that they, too, had discussed the experience during deliberations and that the revelation had appeared to help shape the jury’s discussions.” To date, this juror has not publicly revealed their identity, and Ms. Maxwell does not know who it is.!° Applicable Law I. Juror No. 50’s misconduct deprived Ms. Maxwell of her constitutional right to a fair trial by an impartial jury. A. A party alleging unfairness based on undisclosed juror bias must demonstrate first, that the juror’s voir dire response was false and 8 https://www.dailymail.co.uk/news/article-10379445/Ghislaine-Maxwells- lawyers-fought-ask-jurors-detailed-questions-sexual-abuse.html * https://www.nytimes.com/2022/01/05/nyregion/maxwell-trial-jury-inquiry.html m o N — DOJ-OGR-00009720