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Case 1:20-cr-00330-PAE Document 643 _ Filed 03/11/22 Page 20 of 49 The defendant also fails to establish that Juror 50 falsely answered Question 25, when he gave a negative response to the question whether he or relatives or close friends have been the victim of a crime. Juror 50 has not publicly disclosed the particulars of any sexual abuse that he suffered, and thus it is not apparent whether it was in fact a crime. Nor is it apparent that, if the abuse was criminal, Juror 50 deliberately lied when he answered Question 25 in the negative, as lay persons often may not think of themselves as victims of a crime even where lawyers and judges would. See, e.g., Fell, 2014 WL 3697810, at *6-7, *13 (crediting juror’s explanation that she did not disclose past sexual abuse in response to question about whether she had been a victim of a crime because she did not consider the abuse, for which the abuser was never prosecuted, a crime); see also McDonough, 464 U.S. at 555. Finally, the available information does not support the defendant’s claim that Juror 50 lied during voir dire when he (1) stated that he used Facebook and Instagram, without mentioning that he had a Twitter account, and (2) stated that he had deleted his social media accounts prior to trial. (See Nov. 16, 2021 Tr. at 133). First, the screenshot of Juror 50’s Twitter account provided by the defense states that he joined Twitter in April 2021, had only one follower, and only followed 39 people. (Def. Mem. at 18). That hardly bespeaks an active Twitter user, so it was not even inaccurate, much less deliberately false, for Juror 50 not to mention Twitter when asked “What did you use, Facebook, Twitter?” (Nov. 16, 2021 Tr. at 133 (emphasis added)). Second, in support of the argument that Juror 50 lied about deleting his Facebook and Instagram accounts, the defendant cites only post-trial activity on his Instagram account, but as the defendant must acknowledge (Def. Mem. at 20), a deleted account can be reactivated with a few clicks. Indeed, 18 DOJ-OGR-00009818