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678 KB
Extraction Summary
3
People
2
Organizations
0
Locations
2
Events
2
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
678 KB
Summary
This legal filing argues that the government is mischaracterizing the record concerning Juror No. 50's responses during jury selection. The document contends that, unlike other jurors, Juror No. 50's specific claim of childhood sexual abuse was directly relevant to the case, and had he disclosed his belief that memory works 'like a video-tape' during the trial, the Court would have questioned his ability to fairly evaluate expert testimony on the topic.
People (3)
| Name | Role | Context |
|---|---|---|
| Juror No. 50 | Juror |
The central figure of the argument, whose answers to a questionnaire and post-verdict media statements about memory a...
|
| Ms. Maxwell | Defendant (implied) |
Mentioned in relation to her expert, Dr. Loftus, and the jurors' ability to accept the expert's testimony.
|
| Dr. Loftus | Expert |
Referred to as Ms. Maxwell's expert, whose testimony on the science of memory was a key part of the trial.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The government | Government agency |
A party in the legal case, whose arguments regarding Juror No. 50 are being refuted in this document.
|
| Court | Judicial body |
The judicial body that presided over the trial and voir dire, and whose actions regarding juror questioning are discu...
|
Timeline (2 events)
The process where potential jurors, including Juror No. 50, were questioned. The document discusses how Juror No. 50 answered Question 48 during this time.
Courtroom (implied)
post-verdict
Juror No. 50 publicly discussed his beliefs about the science of memory, stating that his own memory is like a video-tape.
Media
Relationships (2)
The document refers to 'Ms. Maxwell’s expert, Dr. Loftus'.
The document presents arguments from one party (representing Ms. Maxwell) against the other (the government) in a legal case.
Key Quotes (1)
"his own memory is like a video-tape"Source
— Juror No. 50
(A belief about the science of memory that Juror No. 50 publicly aired in the media after the verdict, which is a central point of the legal argument.)
DOJ-OGR-00009896.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (1,809 characters)
Case 1:20-cr-00330-PAE Document 644 Filed 03/11/22 Page 27 of 32
now correctly answer Question 48 but not give the details as he would have had to do in Question 48a in the event he had correctly answered Question 48 at the time of voir dire. The government also misses the significant point that none of these other jurors disclosed childhood sexual abuse, the facts underlying the charges in this case.
The government also mischaracterizes the record regarding questions to – and potential for cause challenges against –any juror who may have been incapable of accepting the testimony of Ms. Maxwell’s expert, Dr. Loftus. See Resp. at 35-36. The government first only points to the fact that none of the jurors who answered yes to Question 48 were asked about the expert testimony. That is because none of the others – like Juror No. 50 – claimed to have been the victim of childhood sexual abuse, i.e., the charges in this case. Why would anyone have asked whether a groping on the subway as an adult would be replayed like a videotape? Second, this Court inquired of many other potential jurors, including at the request of the government, whether they could put aside their outside knowledge and consider the expert testimony presented at trial. See, e.g., Tr. 489-90, 527-28, 534-39, 666-67, 709-10. There is nothing to suggest that, had Juror No. 50 disclosed his beliefs about the science of memory as he publicly aired post-verdict in the media (that his own memory is like a video-tape), that the Court would not have followed up to inquire whether he could fairly evaluate expert testimony on that topic.
The government also mischaracterizes the record regarding questions to – and potential for cause challenges against –any juror who may have been incapable of accepting the testimony of Ms. Maxwell’s expert, Dr. Loftus. See Resp. at 35-36. The government first only points to the fact that none of the jurors who answered yes to Question 48 were asked about the expert testimony. That is because none of the others – like Juror No. 50 – claimed to have been the victim of childhood sexual abuse, i.e., the charges in this case. Why would anyone have asked whether a groping on the subway as an adult would be replayed like a videotape? Second, this Court inquired of many other potential jurors, including at the request of the government, whether they could put aside their outside knowledge and consider the expert testimony presented at trial. See, e.g., Tr. 489-90, 527-28, 534-39, 666-67, 709-10. There is nothing to suggest that, had Juror No. 50 disclosed his beliefs about the science of memory as he publicly aired post-verdict in the media (that his own memory is like a video-tape), that the Court would not have followed up to inquire whether he could fairly evaluate expert testimony on that topic.
10 The other jurors who also answered affirmatively to question 48 provided the details, as required by the questionnaire, to 48a. See generally Resp. at 4-5; [REDACTED]
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DOJ-OGR-00009896
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