The High Court judge hearing Ian Bailey's damages action has warned the case will have to be aborted if they have fewer than 10 jurors to hear it.
Mr Justice John Hedigan said that scenario would be a disaster for everyone.
The court was unable to sit for a second day today due to the unavailability of a juror.
The action had been scheduled to last around six weeks, but is now expected to run into next year.
Ian Bailey of The Prairie, Schull, Co Cork is suing the State and Garda Commissioner for alleged wrongful arrest in connection with the 1996 murder of Sophie Toscan du Plantier.