DOJ-OGR-00009053.pdf

--- Page 1 --- **Case 1:20-cr-00330-PAE** **Document 613** **Filed 02/24/22** **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.** **16** **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.**17** Had that happened, the record shows that he would have been removed as a potential juror.** **16** 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. **17** This follow-up questioning would not have been a mere formality. **45** **DOJ-OGR-00009053**