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743 KB
Extraction Summary
4
People
3
Organizations
1
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal memorandum (court filing)
File Size:
743 KB
Summary
This document is page 39 of a government legal filing (Document 643) in the case against Ghislaine Maxwell (Case 1:20-cr-00330). The prosecution argues against the defendant's motion to call all twelve jurors as witnesses to investigate potential non-disclosure of sexual abuse, labeling it a 'fishing expedition' damaging to the jury process. The text specifically addresses a New York Times article mentioning a second juror's abuse history and argues that questioning should be strictly limited to Juror 50.
People (4)
| Name | Role | Context |
|---|---|---|
| Juror 50 | Juror/Witness |
Subject of an evidentiary hearing regarding potential juror misconduct; the government argues questioning should be l...
|
| The Defendant | Defendant |
Refers to Ghislaine Maxwell (based on Case 1:20-cr-00330 context); requesting to call all 12 jurors as witnesses.
|
| Anonymous Second Juror | Juror |
Mentioned in a NY Times article as having been sexually abused as a child.
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| Reporter | Journalist |
Interviewer for The New York Times.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| The New York Times |
Newspaper that published an interview with a second juror regarding sexual abuse.
|
|
| Second Circuit |
Court of Appeals cited regarding legal precedents (Ianniello, Moon).
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| DOJ |
Department of Justice (implied by Bates stamp DOJ-OGR).
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Locations (1)
| Location | Context |
|---|---|
|
Venue where the hearing would take place (Southern District of New York implied by case number).
|
Relationships (2)
Served on the same jury (implied); Juror 50 made statements about the other juror.
Defendant is requesting to question Juror 50 and others.
Key Quotes (4)
"Instead, the questioning of Juror 50 should be limited to only what is strictly necessary to determine the relevant issues."Source
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Quote #1
"It would be difficult to imagine a spectacle more damaging to the jury process than requiring each of the jurors to return to court weeks or months after their service was complete to testify about such a deeply personal and sensitive subject."Source
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Quote #2
"The defendant’s request is exactly the sort of “fishing expedition” that presents the “evil consequences” of which the Second Circuit has repeatedly warned."Source
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Quote #3
"The defendant’s request for such an inquisition is based on a single sentence in a newspaper article, which reports that an anonymous “second juror described in an interview with The New York Times having been sexually abused as a child.”"Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,207 characters)
Case 1:20-cr-00330-PAE Document 643 Filed 03/11/22 Page 39 of 49
Mem. at 44). Instead, the questioning of Juror 50 should be limited to only what is strictly
necessary to determine the relevant issues.
necessary to determine the relevant issues.
3. There Is No Basis to Call Any Other Juror as a Witness
There is no basis to call any other witness at a hearing aside from Juror 50. The questioning
of Juror 50 is sufficient to address the only questions as to which the rigorous standard for an
evidentiary hearing has been met.
of Juror 50 is sufficient to address the only questions as to which the rigorous standard for an
evidentiary hearing has been met.
The defendant nevertheless proposes calling each of the twelve jurors for testimony about
whether they have experienced sexual abuse. (Def. Mem. at 50, 57). It would be difficult to
imagine a spectacle more damaging to the jury process than requiring each of the jurors to return
to court weeks or months after their service was complete to testify about such a deeply personal
and sensitive subject. The defendant’s request is exactly the sort of “fishing expedition” that
presents the “evil consequences” of which the Second Circuit has repeatedly warned. See
Ianniello, 866 F.2d at 543; Moon, 718 F.2d at 1234.
whether they have experienced sexual abuse. (Def. Mem. at 50, 57). It would be difficult to
imagine a spectacle more damaging to the jury process than requiring each of the jurors to return
to court weeks or months after their service was complete to testify about such a deeply personal
and sensitive subject. The defendant’s request is exactly the sort of “fishing expedition” that
presents the “evil consequences” of which the Second Circuit has repeatedly warned. See
Ianniello, 866 F.2d at 543; Moon, 718 F.2d at 1234.
The defendant’s request for such an inquisition is based on a single sentence in a newspaper
article, which reports that an anonymous “second juror described in an interview with The New
York Times having been sexually abused as a child.” See
https://www.nytimes.com/2022/01/05/nyregion/maxwell-trial-jury-inquiry.html.17 It is
questionable that this report itself may be considered under Rule 606(b), insofar as the next
sentence refers to the juror’s experience in the context of jury deliberations, so it is not clear from
the article whether the anonymous juror made any statements to the reporter that were separate
article, which reports that an anonymous “second juror described in an interview with The New
York Times having been sexually abused as a child.” See
https://www.nytimes.com/2022/01/05/nyregion/maxwell-trial-jury-inquiry.html.17 It is
questionable that this report itself may be considered under Rule 606(b), insofar as the next
sentence refers to the juror’s experience in the context of jury deliberations, so it is not clear from
the article whether the anonymous juror made any statements to the reporter that were separate
17 The defendant’s motion also states that Juror 50 has made public statements about another juror
who discussed experiences with sexual abuse in the context of deliberations. Rule 606(b)
precludes the Court from considering this. See Warger, 574 U.S. at 43 (affirming denial of motion
for a new trial under McDonough, where the only evidence of juror dishonesty was an affidavit
from another juror regarding statements a juror had made during deliberations).
who discussed experiences with sexual abuse in the context of deliberations. Rule 606(b)
precludes the Court from considering this. See Warger, 574 U.S. at 43 (affirming denial of motion
for a new trial under McDonough, where the only evidence of juror dishonesty was an affidavit
from another juror regarding statements a juror had made during deliberations).
37
DOJ-OGR-00009837
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