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Extraction Summary
3
People
4
Organizations
0
Locations
3
Events
3
Relationships
8
Quotes
Document Information
Type:
Legal document
File Size:
639 KB
Summary
This legal document, dated March 1, 2022, addresses the potential bias of Juror 50 in Case 1:20-cr-00330-PAE. It details questions posed to Juror 50 regarding his recollection of a jury questionnaire about sexual abuse, particularly in light of an interview he gave to a Daily Mail reporter. The document argues that Juror 50's childhood sexual abuse, similar to that of witnesses, is sufficient grounds for a 'for cause' challenge, citing legal precedent on implied and inferable bias.
People (3)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | The Honorable (Judge) |
Addressee of the document, likely the presiding judge in Case 1:20-cr-00330-PAE.
|
| Juror 50 | Juror |
The subject of an inquiry into potential bias due to childhood sexual abuse.
|
| Torres |
Defendant in the cited legal case United States v. Torres.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Daily Mail | newspaper |
Organization whose reporter interviewed Juror 50.
|
| United States | government agency |
Plaintiff in the cited legal case United States v. Torres.
|
| Court | government agency |
The judicial body that should inquire about bias and rule on challenges.
|
| Defense | legal party |
The party making arguments regarding Juror 50's bias.
|
Timeline (3 events)
Relationships (3)
Juror 50 was interviewed by the reporter regarding his jury questionnaire.
The Court is tasked with inquiring into Juror 50's potential bias and ruling on challenges.
Key Quotes (8)
"And when you made that statement to the Daily Mail reporter, you had not seen your jury questionnaire since you had filled it out."Source
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Quote #1
"So, at the time of your interview with the Daily Mail, you recalled a question about whether or not a family member or a relative was sexually abused, but you didn't recall a question about whether you yourself were sexually abused?"Source
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Quote #2
"Question 48 is the only question in the entire questionnaire that asks whether you or a friend or a family member has been the victim of sexual abuse?"Source
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Quote #3
"And the word "you" comes before "friend" and "family member"?"Source
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Quote #4
"So, you're saying that you read this question closely enough at the time you filled out the questionnaire to remember that it asked about sexual abuse involving your friends and family members, but not involving yourself?"Source
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Quote #5
"So, you didn't "fly through" this question – you remember almost all of it?"Source
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Quote #6
"The only part you now claim you "flew through" is the part that asked about your own sexual abuse?"Source
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Quote #7
"Challenges for cause can be based on implied bias, inferable bias, or actual bias."Source
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Quote #8
Full Extracted Text
Complete text extracted from the document (1,867 characters)
Case 1:20-cr-00330-PAE Document 636 Filed 03/01/22 Page 14 of 22
The Honorable Alison J. Nathan
March 1, 2022
Page 14
March 1, 2022
Page 14
e. And when you made that statement to the Daily Mail reporter, you had not seen
your jury questionnaire since you had filled it out.
f. So, at the time of your interview with the Daily Mail, you recalled a question
about whether or not a family member or a relative was sexually abused, but
you didn't recall a question about whether you yourself were sexually abused?
g. Question 48 is the only question in the entire questionnaire that asks whether
you or a friend or a family member has been the victim of sexual abuse?
h. And the word "you" comes before "friend" and "family member"?
i. So, you're saying that you read this question closely enough at the time you
filled out the questionnaire to remember that it asked about sexual abuse
involving your friends and family members, but not involving yourself?
j. So, you didn't "fly through" this question – you remember almost all of it?
k. The only part you now claim you "flew through" is the part that asked about
your own sexual abuse?
your jury questionnaire since you had filled it out.
f. So, at the time of your interview with the Daily Mail, you recalled a question
about whether or not a family member or a relative was sexually abused, but
you didn't recall a question about whether you yourself were sexually abused?
g. Question 48 is the only question in the entire questionnaire that asks whether
you or a friend or a family member has been the victim of sexual abuse?
h. And the word "you" comes before "friend" and "family member"?
i. So, you're saying that you read this question closely enough at the time you
filled out the questionnaire to remember that it asked about sexual abuse
involving your friends and family members, but not involving yourself?
j. So, you didn't "fly through" this question – you remember almost all of it?
k. The only part you now claim you "flew through" is the part that asked about
your own sexual abuse?
C. Questions to Probe Whether Juror 50 Was Biased Due to His Childhood Sexual
Abuse and Could Have Been Struck for Cause
Abuse and Could Have Been Struck for Cause
Apart from the questions set forth above concerning the similarities between Juror 50's
childhood sexual abuse and those of the witnesses—which alone is sufficient to support a for
cause challenge—the Court should inquire about other possible sources of actual, implied, and
inferred bias that may have resulted from his abuse. See United States v. Torres, 128 F.3d 38, 43
(2d Cir. 1997) (Challenges for cause can be based on implied bias, inferable bias, or actual bias).
The defense believes it serves no purpose to ask Juror 50 what he would have said if he had been
childhood sexual abuse and those of the witnesses—which alone is sufficient to support a for
cause challenge—the Court should inquire about other possible sources of actual, implied, and
inferred bias that may have resulted from his abuse. See United States v. Torres, 128 F.3d 38, 43
(2d Cir. 1997) (Challenges for cause can be based on implied bias, inferable bias, or actual bias).
The defense believes it serves no purpose to ask Juror 50 what he would have said if he had been
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