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Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 50 of 66 Fifth, Juror No. 50’s false answer to question 48 was not a one-off mistake. He also falsely answered question 25. Then, during voir dire, he claimed that he used only Facebook and Instagram and that he had deleted both. In fact, he also used Twitter, and it appears he did not delete his Instagram account. This pattern of false answers supports a finding of intent and belies mere inadvertence. Finally, this case is not like other cases in which a juror may have given a false answer to avoid embarrassment,. Juror No. 50 has spoken to numerous media outlets about his service as a juror, has freely admitted that he is the victim of sexual abuse and sexual assault, and has done the bare minimum to conceal his identity, allowing himself to be identified by his first name while posing for pictures and being video recorded. Juror No. 50 has not shunned the limelight. He has reveled in it. D. Had Juror No. 50 answered Questions 25 and 48 truthfully, the parties and the Court would have explored whether his other answers were false. Regardless of whether Juror No. 50’s answers were intentional lies or inadvertent misstatements, his false answers to Questions 25 and 48 cast doubt on the truthfulness of all his answers, including most particularly those questions designed to expose bias based on the nature of charges against Ms. Maxwell—Questions 42-50. At the October 21 hearing, this Court emphasized the importance of voir dire, and it expressed confidence that it could “smoke out” jurors who did not tell the truth: letter was written by the government with full knowledge that it would be published by the media and effectively silence Juror No. 50. The submission of the letter was an end run around this Court’s orders regarding Local Rule 23.1 and Rule 3.6 of the Rules of Professional Conduct. 43 DOJ-OGR- 00009742