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Extraction Summary

4
People
2
Organizations
0
Locations
2
Events
1
Relationships
2
Quotes

Document Information

Type: Legal document
File Size: 708 KB
Summary

This legal document, filed on March 11, 2022, argues that Juror No. 50 was not impartial and failed to honestly disclose his past as a victim of sexual abuse during jury selection. The filing contends that this omission prevented the Court and defense from properly assessing his ability to be fair, particularly regarding the testimony of Dr. Loftus and the defense of Ms. Maxwell. The document suggests that had the juror been truthful, further inquiry would have been made, and his claim of impartiality is not credible.

People (4)

Name Role Context
Juror No. 50 Juror
The central figure of the document, accused of not honestly answering questions during voir dire, which allegedly pre...
Dr. Loftus Witness
Mentioned as a witness whose testimony Juror No. 50 may have been unable to fairly evaluate due to his personal exper...
Ms. Maxwell Defendant
The defendant in the case, whose defense Juror No. 50 was allegedly unable to impartially assess.
Wainwright
Mentioned in a legal citation (Wainwright, 469 U.S. at 424) related to a juror's duties.

Organizations (2)

Name Type Context
Court government agency
The judicial body that was allegedly not alerted to issues with Juror No. 50's impartiality.
government government agency
The prosecuting party whose burden of proof Juror No. 50 was tasked with evaluating.

Timeline (2 events)

2021-10-21
A transcript (TR) from this date is quoted regarding the process of questioning jurors (voir dire).
Court
Juror No. 50 allegedly failed to honestly answer material questions (specifically Question 48 and Question 25) about his past experiences as a victim of sexual abuse and a victim of a crime.
Court

Relationships (1)

Juror No. 50 legal (juror-defendant) Ms. Maxwell
The document argues that Juror No. 50 was not fair and impartial in his role as a juror for Ms. Maxwell's trial due to his undisclosed personal history, which allegedly prevented him from impartially assessing her defense.

Key Quotes (2)

"I will individually, one-on-one, question[] the jurors, and with the parties present, I feel confident that I can discern any clear dishonesty. This is not just going to be a summary voir dire; it will be probing. . . . If a juror’s going to lie and be dishonest, we will smoke that out."
Source
— Unidentified (from TR 10/21/2021) (Quoted from a court transcript to illustrate the intended thoroughness of the jury selection process.)
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Quote #1
"prevent[ed] or substantially impair[ed] the performance of his duties as a juror in accordance with his instructions and his oath."
Source
— Juror No. 50 (A description of the effect of Juror No. 50's personal experiences, based on what he has said to the media, and cited in the context of a legal standard from Wainwright.)
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Quote #2

Full Extracted Text

Complete text extracted from the document (1,946 characters)

Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 51 of 66
I will individually, one-on-one, question[] the jurors, and with the parties
present, I feel confident that I can discern any clear dishonesty. This is not
just going to be a summary voir dire; it will be probing. . . . If a juror’s going
to lie and be dishonest, we will smoke that out.
TR 10/21/2021, p 25-26. Because Juror No. 50 did not honestly answer these material
questions, however, the Court and the defense were not alerted to probe these issues and
instead relied on Juror No. 50’s claim that he could be fair and impartial. In hindsight,
that claim is not credible.
This is not speculation. Rather, based on what Juror No. 50 has said to the media,
it’s clear he was not fair and impartial because his personal experiences “prevent[ed] or
substantially impair[ed] the performance of his duties as a juror in accordance with his
instructions and his oath.” Wainwright, 469 U.S. at 424. If Juror No. 50 had truthfully
disclosed that he was a victim of sexual assault and sexual abuse as a child, the Court and
parties would have probed, among other things, whether he was able (1) to assess the
credibility of alleged sex assault victim like all other witnesses; (2) to fairly evaluate the
testimony of Dr. Loftus; (3) to impartially assess Ms. Maxwell’s defense that her
accusers’ memories were unreliable and tainted by money and manipulation; and (4) set
aside his own traumatic experience when evaluating whether the government met its
burden of proof beyond a reasonable doubt.
Juror No. 50’s failure to disclose that he was a victim of sexual abuse (Question
48) was further compounded by his failure to disclose that he was merely a victim of a
crime (Question 25). Disclosing that he was a crime victim would have invited inquiry
by counsel and the Court regarding the nature of the crime and would have provided a
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