DOJ-OGR-00020902.pdf

Case 22-1426, Document 58, 02/28/2023, 3475901, Page76 of 221 A-276 26 M3BTMAX1 1 questions. Do you recall that? 2 A. Yes, your Honor. 3 Q. So if you had filled out your questionnaire accurately as 4 evidence presented at trial and my Instructions as to the law? 5 A. Yeah. No, your Honor, I would be able to review the 6 evidence based solely on the evidence, and if you 7 Q. Okay. At the time I asked you questions, did you believe there's anything about 8 your experience with prior sexual abuse that would interfere 9 with your ability to assess the credibility of witnesses 10 alleging sexual abuse? 11 A. Absolutely in no way. 12 Q. So at the time did you believe that you would be able to 13 conclude that a witness alleging sexual abuse was not 14 testifying truthfully, if that was what the evidence suggested? 15 A. Correct, your Honor, yes, I did. 16 Q. At the time I asked you questions on November 16, did you 17 harbor any bias against Ms. Maxwell? 18 A. Not at all. 19 Q. At the time I asked you questions on November 16, were you 20 biased in favor of the government or with 21 the prosecution? 22 Q. Did you want to put your thumb on the scale in any 23 direction? 24 A. No. 25 Q. At the time I asked you questions, and in light of your experience with sexual abuse, did you believe that this subject: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 25 M3BTMAX1 1 questions. Do you recall that? 2 A. Yes, your Honor. 3 Q. So if you had filled out your questionnaire accurately as 4 evidence presented at trial and my Instructions as to the law? 5 A. Yeah. No, your Honor, I would be able to review the 6 evidence based solely on the evidence, and if you 7 Q. Okay. At the time I asked you questions, did you believe there's anything about 8 your experience with prior sexual abuse that would interfere 9 with your ability to assess the credibility of witnesses 10 alleging sexual abuse? 11 A. Absolutely in no way. 12 Q. So at the time did you believe that you would be able to 13 conclude that a witness alleging sexual abuse was not 14 testifying truthfully, if that was what the evidence suggested? 15 A. Correct, your Honor, yes, I did. 16 Q. At the time I asked you questions on November 16, did you 17 harbor any bias against Ms. Maxwell? 18 A. Not at all. 19 Q. At the time I asked you questions on November 16, were you 20 biased in favor of the government or with 21 the prosecution? 22 Q. Did you want to put your thumb on the scale in any 23 direction? 24 A. No. 25 Q. At the time I asked you questions, and in light of your experience with sexual abuse, did you believe that this subject: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00020902