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619 KB
Extraction Summary
7
People
3
Organizations
0
Locations
1
Events
2
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
619 KB
Summary
This legal document, filed on February 24, 2022, is part of a motion on behalf of Ms. Maxwell arguing for a new trial or other relief due to juror misconduct. The filing contends that Juror No. 50 was not impartial, citing his 'pattern and practice of telling falsehoods' under oath during jury selection (voir dire). The document refutes the government's counterarguments and uses legal precedents like McDonough and Greer to support the claim that the juror's deliberate lies are evidence of bias and that the court would have struck him for cause had the truth been known.
People (7)
| Name | Role | Context |
|---|---|---|
| Stewart |
Mentioned in a legal citation (quoting Stewart, 433 F.3d at 304).
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| Greer |
Mentioned in legal citations (citing Greer, 285 F.3d at 171; Greer, 285 F.3d at 173).
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| Shaoul |
Mentioned in a legal case name, United States v. Shaoul.
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| McDonough |
Mentioned in the context of a legal precedent or test from a case.
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| Daugerdas |
Mentioned in a legal citation (As in Daugerdas).
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| Juror No. 50 | Juror |
A juror whose alleged misconduct (lying during voir dire) is the subject of the legal argument.
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| Ms. Maxwell | Defendant |
The individual on whose behalf the legal argument is being made, arguing that Juror No. 50 was biased.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| district court | government agency |
Referenced as the court that must determine the validity of a challenge to a juror.
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| Court | government agency |
Refers to the court hearing the case, which would have struck Juror No. 50 for cause.
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| United States | government agency |
Mentioned as a party in the case name United States v. Shaoul.
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Timeline (1 events)
The voir dire (jury selection) process during which Juror No. 50 allegedly gave false answers under oath.
Court
Relationships (2)
Ms. Maxwell is arguing that Juror No. 50's misconduct and false statements during jury selection demonstrate he was biased and should have been removed from the jury.
The document outlines Ms. Maxwell's arguments and refutes the 'government's contrary arguments,' indicating they are opposing parties in a legal case.
Key Quotes (2)
"the district court must determine if it would have granted the hypothetical challenge’ if it had known the true facts."Source
— Stewart (cited case)
(Quoted to establish the legal standard for evaluating a juror challenge after the fact.)
DOJ-OGR-00009212.jpg
Quote #1
"The deliberateness of the particular lies evidence[] partiality."Source
— Greer (cited case)
(Quoted to support the argument that Juror No. 50's intentional falsehoods are evidence of his bias.)
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Quote #2
Full Extracted Text
Complete text extracted from the document (1,640 characters)
Case 1:20-cr-00330-PAE Document 616 Filed 02/24/22 Page 22 of 32
“This means that ‘the district court must determine if it would have granted the hypothetical challenge’ if it had known the true facts.” Id. (quoting Stewart, 433 F.3d at 304) (citing Greer, 285 F.3d at 171; United States v. Shaoul, 41 F.3d 811, 816 (2d Cir. 1994) (noting that under the second prong of McDonough, a defendant must have a basis for arguing that the district court is required to sustain his challenge for cause)). As in Daugerdas, and under any reading of McDonough, Juror No. 50’s misconduct demonstrates that he was incapable of being an impartial juror and the Court would have struck him for cause. See id.
The government’s contrary arguments do not withstand scrutiny. Foremost, the government mischaracterizes Ms. Maxwell’s argument and then attempts to shoot down the strawman. Ms. Maxwell does not argue that every person who has been a victim of sexual assault or sexual abuse was subject to a “mandatory” challenge for cause based on implied bias. Ms. Maxwell’s argument is simply that Juror No. 50 was impliedly biased—an argument more than supported by the record, Juror No. 50’s pattern and practice of telling falsehoods to the Court, and the statements of Juror No. 50 himself.
Likewise, the government misunderstands Ms. Maxwell’s argument about Juror No. 50’s false claims [REDACTED TEXT] is part of his pattern and practice of giving false answers under oath during voir dire, in a (successful) attempt to serve as a juror. “The deliberateness of the particular lies evidence[] partiality.” Greer, 285 F.3d at 173.
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DOJ-OGR-00009212
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