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Extraction Summary

2
People
2
Organizations
0
Locations
1
Events
0
Relationships
6
Quotes

Document Information

Type: Legal document
File Size: 692 KB
Summary

This legal document, filed on March 11, 2022, argues that Juror No. 50 is not credible. It cites the juror's nonsensical explanation for a false answer when confronted by a Daily Mail reporter, disputes his claim of having 'flew through' the jury questionnaire by providing evidence of careful completion, and asserts it is unbelievable he would not remember a question about being a victim of sexual assault. The document aims to undermine the juror's truthfulness and fitness to serve.

People (2)

Name Role Context
Juror No. 50 Juror
The subject of the document, whose credibility and answers on a jury questionnaire are being challenged.
Daily Mail reporter Reporter
Told Juror No. 50 about Question 48, prompting a response from the juror.

Organizations (2)

Name Type Context
Daily Mail company
A reporter from this organization spoke to Juror No. 50.
The Court government agency
The judicial body overseeing the case, which would have access to juror questionnaires and could be alerted by jurors...

Timeline (1 events)

Juror No. 50 completed a jury questionnaire. He later claimed he 'flew through' it, but the document argues there is evidence he followed instructions carefully.

Key Quotes (6)

"Interesting,"
Source
— Juror No. 50 (Said in response to being told about Question 48 by a Daily Mail reporter.)
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Quote #1
"No, No! I know my face is red because I can feel the blood but, I honestly—that’s why I answered it that way."
Source
— Juror No. 50 (A nonsensical response given to explain away a false answer on the questionnaire.)
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Quote #2
"flew through"
Source
— Juror No. 50 (The juror's claim about how he completed the questionnaire, which the document argues is not worthy of belief.)
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Quote #3
"carefully"
Source
— Questionnaire instructions (An instruction to potential jurors on how to complete the questionnaire.)
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Quote #4
"only truthful answers"
Source
— Questionnaire instructions (The questionnaire advised jurors that this was the standard for answers, not whether they were 'right or wrong'.)
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Quote #5
"true and correct"
Source
— Juror No. 50 (The juror certified, under penalty of perjury, that his answers were true and correct.)
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Quote #6

Full Extracted Text

Complete text extracted from the document (1,866 characters)

Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 47 of 66
turned red, and he grasped for words when the Daily Mail reporter told him about
Question 48. “Interesting,” Juror No. 50 said, struggling for an explanation. Unable to
credibly explain away his false answer, Juror No. 50 eventually put together a
nonsensical response: “No, No! I know my face is red because I can feel the blood but, I
honestly—that’s why I answered it that way.”
Second, Juror No. 50’s attempt to justify his false answer by claiming he “flew
through” the questionnaire is not worthy of belief. The questionnaire instructed potential
jurors to “carefully” compete it. No time limitation was imposed for completion of the
questionnaire. It emphasized that only the parties and the Court would know the identities
of the jurors. It advised that there are no “right or wrong” answers, “only truthful
answers.” And it assured jurors that their privacy would be respected and that if an
answer to any question was embarrassing or caused the juror particular concern, they
could alert the Court. The Court must presume Juror No. 50 needed these instructions.
Indeed, there is compelling evidence that Juror No. 50 carefully followed these
instructions and did not “fly through” the questionnaire, as he now claims. For example,
he correctly skipped follow-up questions that he did not need to answer if he answered
“no” to the initial question and provided written explanations for some questions when
called to do so. Ex. 1, p 17 (Question 34.a); p 18 (Question 37.a). Juror No. 50 also
certified, under the penalty of perjury, that his answers were “true and correct.” Ex. 1, p
27.
Third, it is simply not credible that Juror No. 50 would not recognize and then not
remember that the questionnaire asked if he was a victim of sexual assault, sexual abuse,
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