DOJ-OGR-00020899.jpg

Case 22-1426, Document 58, 02/28/2023, 3475901, Page73 of 221
A-273

M38TMAX1
19

1 unable to render a verdict. You checked no. 9A said: If yes,
2 please explain. You left that blank. So that question, if a
3 yes response called for explanation, you didn't provide an
4 explanation because you checked no.
5 The next question 10 asked about principles of law and
6 whether you would accept them if selected to serve on the jury,
7 and you said yes. 10A said: If no, please explain. And you
8 followed that instruction and didn't provide an explanation
9 because you had said yes.
10 You recall there were a number of questions that
11 sometimes called for explanation and sometimes didn't?
12 A. Yes, your Honor.
13 Q. So how did you know whether to include follow-up answers?
14 A. So these questions are in the beginning where I had more
15 focus than I did at the end and less distractions, so it was
16 easier to follow along, like these are the first few questions.
17 It is a pretty thick packet, there's a binder of questions, so
18 at this point I was still, I guess, in focus and in the zone
19 and knew how to respond to these questions I guess accurately
20 at this part.
21 Q. Actually throughout the questionnaire you appeared to have
22 followed the instructions with respect to follow-up questions.
23 A. Right.
24 Q. I reviewed a lot of questionnaires. Some people would
25 provide follow-up when it wasn't called for or not provide

SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300

M38TMAX1
20

1 follow-up when it was called for. Your questionnaire seems to
2 follow the instructions throughout. It appears generally that
3 you read and followed the instructions within each question.
4 So how do you reconcile that with what you just testified to
5 that you were distracted, raced through?
6 A. Pretty simply, because you see your answer, you mark a no,
7 then the next question says "if yes." Well, I marked no, so
8 skip, go to the next question. So that's what I'm talking
9 about when I flew through, I skimmed, I didn't read everything.
10 So if I had just marked no and it says "if yes," immediately
11 move on.
12 Q. Just to return to 48 now, sorry to go back, first you told
13 me it was a good question, how long it took you to fill it out,
14 and then you said you couldn't remember. I want to go back. I
15 think you said you were finished by noon. Do you remember what
16 time you started the questionnaire?
17 A. It had to be around 11-something. Again, I don't know,
18 I --
19 Q. I'm not sure that clock works.
20 A. Yeah, I don't remember seeing -- obviously that clock is in
21 the back and I was facing the front of the courtroom that we
22 were in, so I wouldn't have even seen that clock. But I feel
23 like the room we were in was much larger than this one, and I
24 don't know what time I started. It definitely felt like we
25 were there for hours before even seeing your video and then

SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00020899