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Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 64 of 66 For its part, this Court expressed “confidence” that its voir dire process would “smoke out” a juror who was dishonest. Ms. Maxwell relied on the Court’s process. And the Court and the parties relied on the presumption to which everyone is entitled: that potential jurors would carefully and honestly engage in voir dire. Unfortunately, we now know that Juror No. 50 (and at least one other juror) did not honor their obligations to give “only truthful answers.” Ex. 1, p 3. They are no longer entitled to the presumption of honesty. Because Ms. Maxwell’s jury was not the fair and impartial one guaranteed her by the United States Constitution, this Court should vacate the jury’s verdict and order a new trial. In the alternative, this Court should hold an evidentiary hearing and examine all twelve jurors. Dated: January 19, 2022 57 DOJ-OGR-00009756