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Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 39 of 66 the victim of a home invasion to harbor bias against a defendant accused of such a crime.” Id. The same is true here: “It would be natural for a juror who had been the victim of [sexual assault and sexual abuse] to harbor bias against a defendant accused of such a crime.” See id. Like Jane, Carolyn, Kate, and Annie Farmer, Juror No. 50 claims to be a victim of child sexual abuse. Like Jane, Carolyn, Kate, and Annie Farmer, Juror No. 50 delayed disclosing the abuse he suffered. Like Jane, Carolyn, Kate, and Annie Farmer, Juror No. 50 says the memories of the abuse he suffered can be “replayed like a video.” And like Jane, who described Mr. Epstein’s New York apartment and said it had a “red mood,” TR at 320, Juror No. 50 says he can remember the “color of the carpet, [of] the walls” in the room where he was abused. These similarities are profound because they bear on the principal argument Ms. Maxwell made against her accusers’ claimed memories: They were corrupted and unreliable. Juror No. 50’s claim that the memory of his abuse can be “replayed like a video” is perhaps most significant, because it directly contradicts Dr. Loftus’s expert testimony: Q. Memory has been termed a constructive process; correct? A. Yes. Q. Could you explain what that means to the jury. A. What we mean by that is as I testified earlier, we don’t just record events and play it back later like a recording device would work, like a video machine, but rather, we are actually constructing our memories when we retrieve memories. We often take bits and pieces of experience sometimes on DOJ-OGR- 00009731