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Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 48 of 66 or sexual harassment. Juror No. 50 said he did remember the questionnaire’s asking whether his family or friends had been victims of sexual assault, sexual abuse, or sexual harassment. But as the questionnaire itself explained and as this Court told Juror No. 50 during his voir dire, the entire point of the process was to evaluate whether Juror No 50 could be fair and impartial. Ex. 1, p 3 (“The purpose of this questionnaire is to determine whether prospective jurors can decide this case impartially based upon the evidence presented at trial and the legal instructions given by the presiding judge.”). The questionnaire also told potential jurors that it would ask personal questions. /d. (“Although some of the questions may appear to be of a personal nature, please understand that the Court and the parties must learn enough information about each juror’s background and experience to select a fair and impartial jury.”’). A personal experience as a victim of sexual assault, sexual abuse, or sexual harassment is far more relevant to fairness and impartiality than a family member’s or friend’s experience with such assault, abuse, or harassment. Given the content of the questionnaire and its obvious purpose, remembering a question about the latter but not the former is simply not credible. Fourth, Juror No. 50’s post-verdict conduct shows his false answers to the questionnaire were intentional. Juror No. 50 went on a media press to promote himself, his experience as a victim, and his role on the jury. He has given multiple interviews to 4] DOJ-OGR-00009740