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Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 42 of 66 a serious concern as to whether an ordinary person in [Juror No. 50’s] shoes would be able to disregard [his] own experiences in evaluating the evidence.” /d. Moreover, like the juror in Ashfar, Juror No. 50’s post-trial conduct further supports a finding of implied bias. The juror in Ashfar communicated with a victim of sexual assault; here, Juror No. 50 communicated with Annie Famer. The juror in Ashfar viewed himself as “advocate for people;” here, Juror No. 50 proclaimed that the verdict against Ms. Maxwell was a verdict “for all the victims.” The bias of Juror No. 50 should be implied for another reason: “[R]epeated lies in voir dire imply that the juror concealed material facts in order to secure a spot on the particular jury.” Daugerdas, 867 F. Supp. 2d at 472. Here, not only did Juror No. 50 falsely deny on the questionnaire that he had been a victim of a crime and a victim of sexual assault and sexual abuse, he also falsely answered the Court’s questions about social media. According to Juror No. 50, he used only Facebook and Instagram and he deleted all his social media accounts. In fact, Juror No. 50 was a Twitter user, having joined Twitter in April 2021. His Twitter account appears to have been active during trial and voir dire, notwithstanding his claim that he deleted all his social media accounts. Moreover, after trial, Juror No. 50 used Twitter to publicize his interviews with the press and to communicate directly to Annie Farmer. It also appears Juror No. 50 did not delete his Instagram account. Crucially, “[e]ven when prospective jurors are dishonest for reasons other than a desire to secure a seat on the jury, dishonest answers to voir dire questions indicate that a juror 1s unwilling or unable ‘to apply the law as instructed by the court to the evidence 35 DOJ-OGR- 00009734