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Extraction Summary
5
People
2
Organizations
0
Locations
2
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
715 KB
Summary
This legal document, part of case 1:20-cr-00330-PAE filed on February 24, 2022, presents an argument on behalf of Ms. Maxwell that Juror No. 50 intentionally provided false answers to questions during the jury selection process (voir dire). The document asserts that Ms. Maxwell can meet the burden of proof to show the juror's dishonesty and that the court should infer bias, citing legal precedents to support its claims. The filing suggests that video evidence of the juror being confronted with the false answers supports the claim of intentional deception.
People (5)
| Name | Role | Context |
|---|---|---|
| Juror No. 50 | Juror |
The subject of the legal argument, accused of providing intentionally false answers during voir dire.
|
| Ms. Maxwell | Party to the case |
The individual arguing that Juror No. 50 was biased and intentionally provided false answers.
|
| Haynes | Party in a cited case |
Mentioned in the case citation United States v. Haynes.
|
| Rosales-Lopez | Party in a cited case |
Mentioned in the case citation Rosales-Lopez v. United States.
|
| Stewart | Party in a cited case |
Mentioned in the case citation Stewart, 433 F.3d at 303.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States | government |
Cited as a party in the legal cases United States v. Haynes and Rosales-Lopez v. United States.
|
| Court | judicial body |
The judicial body presiding over the case involving Ms. Maxwell and Juror No. 50.
|
Timeline (2 events)
The voir dire (jury selection) process during which Juror No. 50 allegedly gave false answers to questions 25 and 48 of a questionnaire.
Court
A potential future evidentiary hearing where Juror No. 50 would be compelled to give truthful answers.
Court
Relationships (1)
Ms. Maxwell is arguing that Juror No. 50 intentionally misled the court with false answers during jury selection, implying a challenge to the juror's impartiality and fitness to serve on her case.
Key Quotes (3)
"based upon express proof, e.g., by a voir dire admission by the prospective juror of a state of mind prejudicial to a party’s interest"Source
— United States v. Haynes, 398 F.2d 980, 984 (2d Cir. 1968)
(Cited as legal precedent defining actual bias.)
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Quote #1
"Without an adequate voir dire the trial judge’s responsibility to remove prospective jurors who will not be able impartially to follow the court’s instructions and evaluate the evidence cannot be fulfilled."Source
— Rosales-Lopez v. United States, 451 U.S. 182, 188 (1981) (plurality opinion)
(Cited as legal precedent on the importance of the voir dire process.)
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Quote #2
"first, that the juror’s voir dire response was false and second, that the correct response would have provided a valid basis for a challenge for cause."Source
— Stewart, 433 F.3d at 303
(Cited as the standard of proof Ms. Maxwell needs to meet.)
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Quote #3
Full Extracted Text
Complete text extracted from the document (1,911 characters)
Case 1:20-cr-00330-PAE Document 613 Filed 02/24/22 Page 46 of 66
based upon the juror’s voir dire answers.” Id. (citing United States v. Haynes, 398 F.2d 980, 984 (2d Cir. 1968) (actual bias is “based upon express proof, e.g., by a voir dire admission by the prospective juror of a state of mind prejudicial to a party’s interest”); Rosales-Lopez v. United States, 451 U.S. 182, 188 (1981) (plurality opinion) (“Without an adequate voir dire the trial judge’s responsibility to remove prospective jurors who will not be able impartially to follow the court’s instructions and evaluate the evidence cannot be fulfilled.”)).
This Court need not decide whether Juror No. 50 was actually biased, since this Court can and should imply and infer bias. Assuming this Court holds an evidentiary hearing at which Juror No. 50 is compelled to give truthful answers to the questions he would have been asked if he had not falsely responded to the questionnaire, Ms. Maxwell reserves the right to argue that Juror No. 50 was actually biased.
C. Juror No. 50’s answers to Questions 25 and 48 were intentionally false.
Ms. Maxwell does not need to prove that Juror No. 50’s voir dire answers were intentionally false. As explained above, she need only prove “first, that the juror’s voir dire response was false and second, that the correct response would have provided a valid basis for a challenge for cause.” Stewart, 433 F.3d at 303. Nevertheless, assuming this Court concludes that Ms. Maxwell must prove Juror No. 50 intentionally misled the Court in falsely answering Questions 25 and 48, Ms. Maxwell has easily met that burden.
There are at least six reasons to believe Juror No. 50 acted intentionally. First, this Court need only watch the video of Juror No. 50 being confronted with his false answers to appreciate that he acted intentionally. Juror No. 50’s face immediately flushed and
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