DOJ-OGR-00021127.pdf

Case 22-1426, Document 59, 02/28/2023, 3475902, Page80 of 113 C. Juror No. 50's False Responses Deprived Ms. Maxwell of her Constitutional Right to a Trial by an Impartial Jury 1. Juror 50 Did Not Truthfully Answer Material Questions During Voir Dire Juror No. 50's answers to Questions 25,48, and 49 were indisputably false. Juror Questionnaire at A289 At the hearing, Juror No. 50 admitted that he gave multiple false answers during voir dire which resulted in the concealment of his experience as a victim of child sexual abuse but denied that his misstatements were intentional. Of some 50 questions, only questions that would have revealed his sexual abuse history were answered incorrectly. Juror 50 denied that he had ever been a victim of a crime because he was thinking about other types of crime and because his "healing process" meant that he did not consider himself a victim (#25); denied that he was the victim of sexual abuse because he was distracted and misread the question (#48); and denied that he had a family member who had been accused of a crime because he did not think of his step-brother who sexually abused him as family (#49). A268-270. 65 DOJ-OGR-00021127