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Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 47 of 66 turned red, and he grasped for words when the Daily Mail reporter told him about Question 48. “Interesting,” Juror No. 50 said, struggling for an explanation. Unable to credibly explain away his false answer, Juror No. 50 eventually put together a nonsensical response: “No, No! I know my face 1s red because I can feel the blood but, I honestly—that’s why I answered it that way.” Second, Juror No. 50’s attempt to justify his false answer by claiming he “flew through” the questionnaire is not worthy of belief. The questionnaire instructed potential jurors to “carefully” compete it. No time limitation was imposed for completion of the questionnaire. It emphasized that only the parties and the Court would know the identities of the jurors. It advised that there are no “right or wrong” answers, “only truthful answers.” And it assured jurors that their privacy would be respected and that if an answer to any question was embarrassing or caused the juror particular concern, they could alert the Court. The Court must presume Juror No. 50 heeded these instructions. Indeed, there is compelling evidence that Juror No. 50 carefully followed these instructions and did not “fly through” the questionnaire, as he now claims. For example, he correctly skipped follow-up questions that he did not need to answer if he answered “no” to the initial question and provided written explanations for some questions when called to do so. Ex. 1, p 17 (Question 34.a); p 18 (Question 37.a). Juror No. 50 also certified, under the penalty of perjury, that his answers were “true and correct.” Ex. 1, p Ds Third, it is simply not credible that Juror No. 50 would not recognize and then not remember that the questionnaire asked if he was a victim of sexual assault, sexual abuse, 40 DOJ-OGR-00009739