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Case 1:20-cr-00330-PAE Document 649 Filed 03/15/22 Page 9 of 12
LAW OFFICES OF BOBBI C. STERNHEIM

process and it’s how I dealt with the abuse.”). Juror 50 elaborated on this statement later in the
Hearing:

I don’t really think about my abuse really much anymore because it doesn’t
define me, it doesn’t make me who I am today. It’s something that happened,
it’s an experience that I lived through, and I have become the person I am today
because of my goals and ambitions. And I do not feel that I am 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.

(Tr. 16). Juror 50’s answers are telling. First, it shows that the abuse was, understandably, such
a traumatic experience in his life and that he needed to undergo a “healing process” to be able to
deal with the abuse. Indeed, Juror 50 disclosed on social media that he sees a therapist regularly
who, among other things, gave him help “dealing with the stress of the [Maxwell] case.”
(Motion at 20). Second, it shows that as part of the healing process, Juror 50 does not identify as
a victim and rejects that label. We do not question in any way the strategies that Juror 50 has
used to cope with and heal from his traumatic experience. However, his statements do reveal
just how deeply the trauma affected him and continues to affect him. The objectively correct
answer to Question 25 is “yes” if you have been the victim of sexual abuse. That is how a
neutral, unbiased juror would have answered that question. But for Juror 50, the question used a
label that sparked an immediate negative reaction that was tied up with the healing process he
has used to deal with his trauma and prevented him from answering accurately. His response
shows quite clearly that Juror 50 was too biased to serve as a juror in this case.²

Third, Juror 50’s answers about why he did not mark “yes (friend or family member)” to
Question 49 are also not credible. After disclosing that he was abused by his stepbrother and that
his mother reported the abuse to the police after he disclosed it, the Court asked Juror 50 why he

² The Court denied the defense’s request to ask further questions about Juror 50’s healing process. We believe that
those questions were relevant and appropriate. Accordingly, we reiterate our objection to the Court’s denial of those
questions and the others posed by defense counsel in its letter submission and at sidebar during the hearing.

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