DOJ-OGR-00021744.jpg
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Extraction Summary
3
People
3
Organizations
0
Locations
4
Events
2
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
716 KB
Summary
This document is the table of contents for a legal filing in Case 22-1426, dated July 27, 2023. The filing presents two main arguments on behalf of Ms. Maxwell: first, that a non-prosecution agreement makes her a third-party beneficiary and bars the USAO-SDNY from prosecuting her, and second, that the District Court erred by not removing Juror 50 for cause after the juror provided dishonest testimony and concealed information about being a victim of child sex abuse during voir dire.
People (3)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Appellant / Third-Party Beneficiary |
Mentioned as the central figure in the legal arguments, specifically as a third-party beneficiary of a non-prosecutio...
|
| Annabi |
Mentioned in the context of the Co-Conspirators Provision of the Non-Prosecution Agreement, which is said to bind the...
|
|
| Juror 50 | Juror |
A juror accused of concealing material information and giving false answers during Voir Dire, and later lying in a Po...
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| USAO-SDNY | government agency |
The United States Attorney's Office for the Southern District of New York, which was allegedly barred from prosecutin...
|
| The Court | government agency |
Refers to the judicial body that failed to hold a hearing on the scope of the non-prosecution agreement and that hear...
|
| THE DISTRICT COURT | government agency |
Specifically mentioned as having erred in crediting a juror's dishonest testimony.
|
Timeline (4 events)
Case 22-1426, Document 87, filed on 07/27/2023.
Relationships (2)
The document outlines Ms. Maxwell's legal arguments against prosecution by the USAO-SDNY, based on a non-prosecution agreement.
Full Extracted Text
Complete text extracted from the document (2,053 characters)
Case 22-1426, Document 87, 07/27/2023, 3548202, Page2 of 35
TABLE OF CONTENTS
Page
TABLE OF AUTHORITIES................................................................................................... iii
PRELIMINARY STATEMENT IN REPLY ..........................................................................1
POINT I
(Point I in Appellant’s Principal Brief)
MS. MAXWELL IS A THIRD-PARTY BENEFICIARY OF A
NON-PROSECUTION AGREEMENT WHICH, BY ITS TERMS,
BARRED THE USAO-SDNY FROM PROSECUTING MS.
MAXWELL FOR THESE OFFENSES..................................................................................2
(Point I in Appellant’s Principal Brief)
MS. MAXWELL IS A THIRD-PARTY BENEFICIARY OF A
NON-PROSECUTION AGREEMENT WHICH, BY ITS TERMS,
BARRED THE USAO-SDNY FROM PROSECUTING MS.
MAXWELL FOR THESE OFFENSES..................................................................................2
A. Ms. Maxwell has Standing to Enforce the Non-Prosecution
Agreement as a Third-Party Beneficiary................................................................3
Agreement as a Third-Party Beneficiary................................................................3
B. The Co-Conspirators Provision of the Non-Prosecution
Agreement Binds the USAO-SDNY and Annabi is not to the
Contrary...................................................................................................................7
Agreement Binds the USAO-SDNY and Annabi is not to the
Contrary...................................................................................................................7
C. The Court’s Failure to Hold a Hearing on the Scope of the
Non-Prosecution Agreement is an Error ............................................................11
Non-Prosecution Agreement is an Error ............................................................11
POINT II
(Point IV in Appellant’s Principal Brief)
THE DISTRICT COURT ERRED IN CREDITING A JUROR’S
PATENTLY DISHONEST TESTIMONY OFFERED TO
EXPLAIN FALSE ANSWERS TO MATERIAL QUESTIONS IN
VOIR DIRE AND FURTHER ERRED IN CONCLUDING THAT
HONEST ANSWERS TO THOSE SAME QUESTIONS WOULD
HAVE NOT PROVIDED A VALID BASIS TO REMOVE THE
JUROR FOR CAUSE.......................................................................................................13
(Point IV in Appellant’s Principal Brief)
THE DISTRICT COURT ERRED IN CREDITING A JUROR’S
PATENTLY DISHONEST TESTIMONY OFFERED TO
EXPLAIN FALSE ANSWERS TO MATERIAL QUESTIONS IN
VOIR DIRE AND FURTHER ERRED IN CONCLUDING THAT
HONEST ANSWERS TO THOSE SAME QUESTIONS WOULD
HAVE NOT PROVIDED A VALID BASIS TO REMOVE THE
JUROR FOR CAUSE.......................................................................................................13
A. Juror 50 Concealed Material Information in Voir Dire by
Giving False Answers on a Juror Questionnaire and Then
Lied About it to the Court in a Post-Verdict Hearing ........................................13
Giving False Answers on a Juror Questionnaire and Then
Lied About it to the Court in a Post-Verdict Hearing ........................................13
B. Had Juror 50 Disclosed in Voir Dire his Traumatic
Experience as a Victim of Child Sex Abuse, the Information
Would Have Established a Valid Basis for a Cause Challenge ........................16
Experience as a Victim of Child Sex Abuse, the Information
Would Have Established a Valid Basis for a Cause Challenge ........................16
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DOJ-OGR-00021744
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