DOJ-OGR-00009883.jpg
702 KB
Extraction Summary
13
People
2
Organizations
0
Locations
2
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
702 KB
Summary
This legal document, filed on March 11, 2022, is part of a motion on behalf of Ms. Maxwell arguing for a new trial. The central claim is that she does not need to prove that Juror No. 50's false answers during jury selection were deliberately made. The document cites multiple legal precedents to support the argument that even an honest but mistaken answer from a juror can be grounds for a new trial, especially when it raises questions of juror bias.
People (13)
| Name | Role | Context |
|---|---|---|
| Juror No. 50 | Juror |
Mentioned as having publicly admitted to making false answers during voir dire, which is the basis for Ms. Maxwell's ...
|
| Ms. Maxwell | Defendant |
The subject of the legal motion, arguing for a new trial based on a juror's false answers. The document is likely a f...
|
| Connick |
Party in the legal case Connick v. Thompson, cited as precedent.
|
|
| Thompson |
Party in the legal case Connick v. Thompson, cited as precedent.
|
|
| Greenwood |
Party in the legal case McDonough Power Equip. v. Greenwood, cited as precedent.
|
|
| Zerka |
Party in the legal case Zerka v. Green, cited as precedent.
|
|
| Green |
Party in the legal case Zerka v. Green, cited as precedent.
|
|
| Dyer |
Party in the legal case Dyer v. Calderon, cited as precedent.
|
|
| Calderon |
Party in the legal case Dyer v. Calderon, cited as precedent.
|
|
| Amirault |
Party in the legal case Amirault v. Fair, cited as precedent.
|
|
| Fair |
Party in the legal case Amirault v. Fair, cited as precedent.
|
|
| Cannon |
Party in the legal case Cannon v. Lockhart, cited as precedent.
|
|
| Lockhart |
Party in the legal case Cannon v. Lockhart, cited as precedent.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| McDonough Power Equip. | company |
Party in the legal case McDonough Power Equip. v. Greenwood, cited as precedent.
|
| United States | government agency |
Mentioned in the context of the government's "solemn duty to seek justice and not merely to convict."
|
Timeline (2 events)
Voir dire process during which Juror No. 50 allegedly provided false answers.
Relationships (2)
The document centers on Ms. Maxwell's motion for a new trial based on the alleged false answers provided by Juror No. 50 during the jury selection process (voir dire).
The document presents arguments on behalf of Ms. Maxwell against the position taken by the government regarding her motion for a new trial.
Key Quotes (5)
"Prosecutors have a special “duty to seek justice, not merely to convict.”"Source
— Connick v. Thompson, 563 U.S. 51, 65-66 (2011)
(Cited to argue that the government's position casts doubt on its duty to seek justice.)
DOJ-OGR-00009883.jpg
Quote #1
"Ms. Maxwell does not have to prove that Juror No. 50’s voir dire answers were deliberately false."Source
— Author of the document
(A heading for a section arguing the legal standard for a new trial.)
DOJ-OGR-00009883.jpg
Quote #2
"does not entirely foreclose a party from seeking a new trial on the basis of a prospective juror’s honest, though mistaken, response."Source
— Zerka v. Green, 49 F.3d 1181, 1186 n.7 (6th Cir. 1995)
(Quoted from a legal precedent to counter the government's argument that deliberate falsehood must be proven.)
DOJ-OGR-00009883.jpg
Quote #3
"In extraordinary cases, courts may presume bias based on the circumstances."Source
— Dyer v. Calderon, 151 F.3d 970, 981 (9th Cir. 1998)
(Cited as legal precedent to support the argument for a new trial.)
DOJ-OGR-00009883.jpg
Quote #4
"[T]he majority vote in McDonough. . . require[s] a further determination on the question of juror bias even where a juror is found to have been honest. . . ."Source
— Amirault v. Fair, 968 F.2d 1404, 1405-06 (1st Cir. 1992)
(Cited as legal precedent to argue that juror honesty does not preclude an inquiry into bias.)
DOJ-OGR-00009883.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,074 characters)
Case 1:20-cr-00330-PAE Document 644 Filed 03/11/22 Page 14 of 32
in a “documentary.” Inquiring into the false answers Juror No. 50 has publicly admitted making risks nothing that Juror No. 50 hasn’t already brought on himself.
Ms. Maxwell’s motion has nothing to do with her innocence or guilt. It involves no strategy or artifice by the defense. And it risks no unauthorized inquiry into the jury room. The motion is about one thing, and one thing only: Every person’s constitutional right to a fair and impartial jury. The government hopes to deprive Ms. Maxwell of that right in the name of “finality.”
This Court should disregard the government’s policy arguments, which address arguments and claims Ms. Maxwell is not making. In turn, the government’s policy arguments betray the weakness of its legal position. And they cast significant doubt on the United States solemn duty to seek justice and not merely to convict. Connick v. Thompson, 563 U.S. 51, 65-66 (2011) (“Prosecutors have a special “duty to seek justice, not merely to convict.”).
B. Ms. Maxwell does not have to prove that Juror No. 50’s voir dire answers were deliberately false.
The government insists that Ms. Maxwell is entitled to a new trial only if she can prove that Juror No. 50 deliberately provided false answers during voir dire. Not so.
Contrary to the government’s argument, the decision McDonough Power Equip. v. Greenwood, “does not entirely foreclose a party from seeking a new trial on the basis of a prospective juror’s honest, though mistaken, response.” Zerka v. Green, 49 F.3d 1181, 1186 n.7 (6th Cir. 1995); accord Dyer v. Calderon, 151 F.3d 970, 981 (9th Cir. 1998) (en banc) (“In extraordinary cases, courts may presume bias based on the circumstances.”); Amirault v. Fair, 968 F.2d 1404, 1405-06 (1st Cir. 1992) (“[T]he majority vote in McDonough. . . require[s] a further determination on the question of juror bias even where a juror is found to have been honest. . . .”), cert. denied, 506 U.S. 1000; Cannon v. Lockhart, 850 F.2d 437, 440 (8th Cir.
9
DOJ-OGR-00009883
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document