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Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 43 of 66 presented by the parties’ and, therefore, are indicative of a lack of impartiality because a fundamental instruction in every federal case 1s that a juror must render a verdict ‘solely on the evidence presented at trial.’” Sampson, 820 F. Supp. 2d at 165 (quoting Thomas, 116 F.3d at 617 & n.10 (citing The Federal Judicial Center’s Benchbook for U.S. District Court Judges)). Therefore, dishonest answers are a factor that can contribute to a finding of implied bias. See Skaggs, 164 F.3d at 517. The false answers Ms. Maxwell knows about so far, by themselves, provide a basis for a new trial because, 1f they had been exposed during voir dire, this Court would have treated Juror No. 50 just as it treated Juror No. 55. As explained above, Juror No. 55 was dismissed for cause when the Court, at defense counsel’s request, confronted him with his Twitter account after he falsely denied using Twitter. TR 11/16/2021, pp 155-59. Here, too, Juror No. 50 falsely denied having a Twitter account. It also appears that he was not telling the truth when he said he deleted his Instagram account. But he also did much more, falsely denying that he had been a victim of sexual assault or sexual abuse. If Juror No. 55’s false answers “provided a valid basis for a challenge for cause,” Stewart, 433 F.3d at 303, Juror No. 50’s false answers do as well. This Court should treat Juror No. 50 just as it treated Juror No. 55, and on that ground order a new trial. Should this Court hold a hearing, however, it would not be surprising if additional false answers come to light. 36 DOJ-OGR-00009735