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Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 36 of 66 material if it has a natural tendency to influence, or be capable of influencing, the judge who must decide whether to excuse a juror for cause.” (citing Neder v. United States, 527 U.S. 1, 16 (1999) (giving general definition of materiality))). B. Had Juror No. 50 answered Questions 25 and 48 truthfully, his answers would have provided a valid basis for a challenge for cause. The second question is whether truthful responses from Juror No. 50 would have provided a valid basis for a challenge for cause. See Stewart, 433 F.3d at 303. “[T]he test is not whether the true facts would compel the Court to remove a juror for cause, but rather whether a truthful response ‘would have provided a valid basis for a challenge for cause.’” Daugerdas, 867 F. Supp. 2d at 470 (quoting McDonough, 464 U.S. at 556). “An impartial jury is one in which every juror is ‘capable and willing to decide the case solely on the evidence before [him].’” /d. (quoting McDonough, 464 U.S. at 554). “Jurors are instructed that they are to decide the question of a defendant’s guilt based solely on the evidence presented.” /d. (citing United States v. Thomas, 116 F.3d 606, 616- 17 n.10 (2d Cir. 1997). A juror is biased—i.e., not impartial—if his experiences “would ‘prevent or substantially impair the performance of his duties as a juror in accordance with his instructions and his oath.’” Wainwright v. Witt, 469 U.S. 412, 424 (1985) (quoting Adams v. Texas, 448 U.S. 38, 45 (1980)); see also United States v. Torres, 128 F.3d 38, 43 (2d Cir. 1997) Guror who structured financial transactions properly excused for cause in case involving structuring of cash deposits). ay DOJ-OGR- 00009728