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Case 1:20-cr-00330-PAE Document 643 Filed 03/11/22 Page8of 49 moved to strike only one of these jurors for cause—for reasons unrelated to Question 48—and the Court denied that motion. Fifty-eight jurors were qualified at the conclusion of voir dire on November 18, 2021. Nov. 18, 2021 Tr. at 717. The Court agreed to ask the qualified jurors before the parties exercised their peremptory strikes on November 29, 2021 whether they had read or heard anything about the defendant or Epstein and, at defense counsel’s suggestion, whether there was any reason they could not be fair and impartial. See Nov. 17, 2021 Tr. at 622:23-625:2; Nov. 29, 2021 Tr. 727:2-14. At the conclusion of that process, the parties exercised their peremptory strikes. Twelve jurors and six alternates were seated. II. Juror 50’s Questionnaire and Voir Dire Juror 50 completed the juror questionnaire and was questioned by the Court during voir dire. In his juror questionnaire, Juror 50 repeatedly made clear that he could be fair and impartial. For example, in response to Question 13, he indicated that he could decide the case “based solely on the evidence or lack of evidence presented in Court, and not on the basis of conjecture, suspicion, bias, sympathy, or prejudice.” See Def. Ex. 1. He also indicated that he accepted the principle that the law provides that a defendant in a criminal case is presumed innocent and the Government is required to prove guilt beyond a reasonable doubt. See Def. Ex. 1, Question 11. Juror 50 disclosed in his questionnaire that he had read on CNN’s website that the defendant was Epstein’s girlfriend, but he stated that he had not formed an opinion about the defendant’s guilt or innocence, and that he had not formed any opinions that might make it difficult for him to be fair and impartial. See Def. Ex. 1, Questions 34-35. He also wrote that he learned about Epstein from CNN, but that he could be fair and impartial and render a verdict based solely on the evidence presented at trial. See Def. Ex. 1, Questions 36-41. DOJ-OGR-00009806