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This legal document discusses the critical issue of juror impartiality and memory reliability in court proceedings. It references the Sampson v. United States case, where a new penalty-phase hearing was ordered due to a juror's undisclosed personal experiences as a crime victim, drawing parallels to concerns about Juror No. 50's ability to fairly evaluate evidence in the current case. The document also incorporates expert testimony from Dr. Loftus regarding the confidence and accuracy of memories, emphasizing the potential for bias when jurors' personal experiences align with case details.