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Extraction Summary
5
People
2
Organizations
0
Locations
2
Events
1
Relationships
3
Quotes
Document Information
Type:
Court filing / legal brief (government opposition)
File Size:
702 KB
Summary
This document is page 13 of a legal filing (Document 620) from February 25, 2022, in the case United States v. Ghislaine Maxwell. The text presents the Government's argument against the Defendant's motion for a new trial, specifically addressing allegations that 'Juror 50' made false statements during voir dire. The filing cites *Warger v. Shauers* and Federal Rule of Evidence 606(b) to argue that juror testimony regarding internal deliberations or personal experiences (unless 'extraneous') cannot be used to impeach a verdict.
People (5)
| Name | Role | Context |
|---|---|---|
| Maxwell | Defendant |
Referred to in citations 'Maxwell Br. at 50' and 'Maxwell Reply at 23 n.11'; the defendant seeking a new trial.
|
| Juror 50 | Juror |
Juror alleged to have made false statements during voir dire.
|
| Second Juror | Juror |
Another juror mentioned for comparison regarding undisclosed experiences.
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| Warger | Plaintiff (Case Law) |
Refers to Warger v. Shauers, a Supreme Court case precedent.
|
| Shauers | Defendant (Case Law) |
Refers to Warger v. Shauers, a Supreme Court case precedent.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Supreme Court |
Cited as the authority rejecting the defendant's reading of Rule 606.
|
|
| DOJ |
Department of Justice (indicated by Bates stamp DOJ-OGR-00009554).
|
Timeline (2 events)
2022-02-25
Filing of Document 620 in Case 1:20-cr-00330-PAE
Court (implied SDNY)
Defense Counsel
Prosecution
Key Quotes (3)
"Rule 606(b) applies to juror testimony during a proceeding in which a party seeks to secure a new trial on the ground that a juror lied during voir dire."Source
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Quote #1
"Information is 'extraneous' when it is 'external to the jury'—that is, 'publicity and information related specifically to the case the jurors are meant to decide,' rather than 'the general body of experiences that jurors are understood to bring with them to the jury room.'"Source
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Quote #2
"The Defendant’s one-sentence attempt to dismiss Warger because it involved a civil rather than a criminal case is unavailing."Source
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,105 characters)
Case 1:20-cr-00330-PAE Document 620 Filed 02/25/22 Page 13 of 21
content of deliberations” but instead to demonstrate that the second juror made a false statement
during voir dire, like Juror 50 allegedly did. Maxwell Br. at 50. But this reading of Rule 606
has been squarely rejected by the Supreme Court, which held that the “plain meaning” of this
language is that “Rule 606(b) applies to juror testimony during a proceeding in which a party
seeks to secure a new trial on the ground that a juror lied during voir dire.” Warger v. Shauers,
574 U.S. 40, 44 (2014). The Defendant’s one-sentence attempt to dismiss Warger because it
involved a civil rather than a criminal case is unavailing. Maxwell Reply at 23 n.11. It is the
same rule of evidence in issue, and the principles enunciated by the Supreme Court apply here
with equal force.
during voir dire, like Juror 50 allegedly did. Maxwell Br. at 50. But this reading of Rule 606
has been squarely rejected by the Supreme Court, which held that the “plain meaning” of this
language is that “Rule 606(b) applies to juror testimony during a proceeding in which a party
seeks to secure a new trial on the ground that a juror lied during voir dire.” Warger v. Shauers,
574 U.S. 40, 44 (2014). The Defendant’s one-sentence attempt to dismiss Warger because it
involved a civil rather than a criminal case is unavailing. Maxwell Reply at 23 n.11. It is the
same rule of evidence in issue, and the principles enunciated by the Supreme Court apply here
with equal force.
The Defendant may also be suggesting in this argument that Rule 606 does not bar Juror
50’s statements because they concern “extraneous prejudicial information,” which is an
enumerated exception to the rule. See Fed. R. Evid. 606(b)(2)(A). To the extent that argument is
raised, it is meritless. Information is “extraneous” when it is “external to the jury”—that is,
“publicity and information related specifically to the case the jurors are meant to decide,” rather
than “the general body of experiences that jurors are understood to bring with them to the jury
room.” Warger, 574 U.S. at 51 (cleaned up). So, for example, the Supreme Court has held that a
foreperson’s undisclosed experience with a car accident is not extraneous information, even in a
motor-vehicle lawsuit where that failure to disclose could have supported a for-cause strike. Id.
at 42–43. The same is true here, as the second juror’s alleged undisclosed experience “did not
provide either [the juror] or the rest of the jury with any specific knowledge regarding” this
particular case. Id. at 51–52. Rather, as this Court instructed, jurors are expected to bring their
“reason, experience, and common sense” to bear in evaluating witnesses’ credibility and the
50’s statements because they concern “extraneous prejudicial information,” which is an
enumerated exception to the rule. See Fed. R. Evid. 606(b)(2)(A). To the extent that argument is
raised, it is meritless. Information is “extraneous” when it is “external to the jury”—that is,
“publicity and information related specifically to the case the jurors are meant to decide,” rather
than “the general body of experiences that jurors are understood to bring with them to the jury
room.” Warger, 574 U.S. at 51 (cleaned up). So, for example, the Supreme Court has held that a
foreperson’s undisclosed experience with a car accident is not extraneous information, even in a
motor-vehicle lawsuit where that failure to disclose could have supported a for-cause strike. Id.
at 42–43. The same is true here, as the second juror’s alleged undisclosed experience “did not
provide either [the juror] or the rest of the jury with any specific knowledge regarding” this
particular case. Id. at 51–52. Rather, as this Court instructed, jurors are expected to bring their
“reason, experience, and common sense” to bear in evaluating witnesses’ credibility and the
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