DOJ-OGR-00020897.pdf

Case 22-1426, Document 58 .02/28/2023, 3475901, Page71 of 221 A-271 16 M38TMAX1 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 A. Absolutely not. Q. In responding to this question, did you answer no so as to make it more likely that you would be selected for the jury? A. Absolutely not, your Honor. Q. Did your history of sexual abuse motivate you in any way to try to tailor your answers to make it more likely that you would be selected for this jury? A. Not at all, your Honor. Q. At the time you filled out the questionnaire on November 4, did it occur to you that you might personally benefit in any way from being on the jury in this case? A. Not at all, your Honor. Q. I'm going to return to question 25 again, which you have indicated was inaccurately responded to and again discussed this, but I want to just hear directly in response to this question, why did you check no? A. Well, again, I don't really think about abuse. I wasn't thinking about it because it doesn't define me today. It's something that happened, and I have lived through it, and I became the person I am today because of my goals and ambitions. And I do not feel that I'm a victim of a crime, even though looking back on this abuse, that does make me a victim of a crime, which is why I should have marked yes for self. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 15 M38TMAX1 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 Q. There are other questions on the questionnaire that are structured with similar yes, yes self, yes friend or family, or no. Do you recall seeing those questions? A. Only after I reread this do I recall that. Q. So none of the questions that included you, self, yes friend or family member, or no - A. I did not pick up on that when I was filling this out. Q. Okay. When did you first learn that an answer to the questionnaire was inaccurate? A. When an article had come out about Lucia through The Independent. Q. So you learned of an inaccurate answer in an article about an interview? A. Yes. Q. And what about during the interview? A. No. Q. During the interview, when did you first learn that the questionnaire may contain questions about sexual abuse history? A. That was during my Daily Mail interview with the reporter Laura Collins. Q. So we're talking about your response to 18 which you have indicated was inaccurate. Did you in any way intentionally provide an inaccurate answer to this question? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00020897