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Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 52 of 66 basis for a cause challenge or a peremptory challenge. Juror No. 50’s false answers to both questions deprived the Court of any basis for any meaningful inquiry on a topic bearing directly on his ability to serve impartially and the basis for a cause challenge. In addition, the failure to be truthful on both questions cannot be purely accidental; rather, it suggests the juror’s intention to shield disqualifying information to advance a desire to serve, which he has now exploited for self-promotion. !° We know, moreover, that Juror No. 50 gave at least one other false answer during voir dire. He falsely said he only used Facebook and Instagram, and he did not mention Twitter, despite being specifically asked about it. He also said that he deleted his social media accounts. That was not true since, as we now know, he used Twitter to publicize his interviews with the press and to communicate directly to Annie Farmer and then posted on Instagram about his service as a juror. Truthful answers from Juror No. 50 would have led the Court and the parties to probe much more deeply into his biases and prejudices, both known and unknown.'’ Had that happened, the record shows that he would have been removed as a potential juror. ‘6 Juror No. 50 continues his media exploits despite being the subject of this Motion and represented by counsel. On January 18, 2022, he appeared in a documentary produced by ITV. See https://www.youtube.com/watch?v=SvnwRuDfrdM at timestamps 01:53, 02:32, 04:10, 05:10, 34:36, 38:41, 39:15. '7 This follow-up questioning would not have been a mere formality. We know, for example, that that Juror No. 55 did not truthfully answer the Court’s questions about social media use, and it took follow-up questioning proposed by defense counsel to “smoke out” his falsehoods. 45 DOJ-OGR-00009744