Efforts to obtain comment from male jurors were unsuccessful.
"The questions from jurors during jury selection and during deliberations are good, on the point," he said.
And she cried on the stand, possibly drawing sympathy from jurors.
The remark brought laughs from several jurors, including the newest one.
Tuesday's note was the fourth from jurors since deliberations began on Thursday.
Desperate notes came out from individual jurors seeking to be removed from the case.
Federal law requires unanimity from jurors to recommend a death sentence.
The defense team had requested that at least certain portions of it be withheld from jurors.
He argued that the entire case should continue despite complaints from several jurors about the length and conduct of the trial.
What we want is a discerning evaluation from individual jurors about the lack of evidence.