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670 KB

Extraction Summary

2
People
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Organizations
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Locations
2
Events
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Relationships
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Quotes

Document Information

Type: Legal document
File Size: 670 KB
Summary

This legal document, part of a court filing, argues that Juror No. 50 should not be granted discovery, specifically a copy of his questionnaire, in advance of a hearing regarding his alleged misconduct. The filing contends that the juror's presence on the jury violated Ms. Maxwell's Sixth Amendment rights to a fair trial, constituting a reversible error that should lead the Court to vacate the verdict.

People (2)

Name Role Context
Juror No. 50 Juror
Accused of misconduct, deliberately misstating information, and violating Ms. Maxwell's rights. The document argues h...
Ms. Maxwell Defendant (implied)
The subject of the trial whose constitutional right to a fair and impartial jury was allegedly violated by Juror No. ...

Organizations (2)

Name Type Context
Twitter company
Mentioned as a platform where Juror No. 50 made communications shortly after the trial.
Instagram company
Mentioned as a platform where Juror No. 50 made communications shortly after the trial.

Timeline (2 events)

A legal trial involving Ms. Maxwell, where Juror No. 50 served on the jury. The fairness of this trial is being contested.
A potential future hearing ordered by the Court to investigate Ms. Maxwell's claims about Juror No. 50's misconduct.
this Court

Relationships (1)

Ms. Maxwell adversarial (legal) Juror No. 50
Ms. Maxwell's legal team is accusing Juror No. 50 of misconduct that undermined her constitutional right to a fair trial.

Key Quotes (3)

"finality"
Source
— government (A word the government allegedly invokes when a juror's false answers favor the prosecution.)
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Quote #1
"disfavor"
Source
— government (A word the government allegedly invokes when a juror's false answers favor the prosecution.)
DOJ-OGR-00009899.jpg
Quote #2
"well, no trial is perfect."
Source
— government (A phrase the government allegedly sighs when a juror's false answers favor the prosecution.)
DOJ-OGR-00009899.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (2,002 characters)

Case 1:20-cr-00330-PAE Document 644 Filed 03/11/22 Page 30 of 32
communications on Twitter and Instagram shortly after trial. Juror No. 50 deliberately mis-stated the date of his closing of his Twitter account and therefore Ms. Maxwell is entitled to discovery in order to prove that deliberate falsehood.
5. Juror No. 50 is not entitled to discovery in advance of the hearing.
Finally, for all the reasons given in the new trial motion and the letters about sealing, Ms. Maxwell maintains that Juror No. 50 should not be provided a copy of the questionnaire, which is currently under seal in this Court. Providing that questionnaire will only distort the search for the truth by allowing Juror No. 50 to further refine his story and excuses. Of course, if this Court orders a hearing, Juror No. 50 will receive his questionnaire at that time. But balanced against Ms. Maxwell’s constitutional right to a fair and impartial jury and this Court’s unflagging duty to investigate Ms. Maxwell’s claim, Juror No. 50’s request for the questionnaire now pales in comparison.
Conclusion
Let there be no doubt. The prosecution’s response is not credible because the government has the luxury of a double standard. If a juror had falsely answered material voir dire questions to favor Ms. Maxwell, the government would not hesitate to prosecute the juror for contempt or perjury. But when, as here, a juror falsely answers voir dire questions to favor the prosecution, the government invokes words like “finality” and “disfavor” and sighs, “well, no trial is perfect.”
But all trials, perfect or not, require a fair and impartial jury. That is non-negotiable. That is the premise and fundamental guarantee of the criminal justice system, a system that was undermined by Juror No. 50’s misconduct.
Juror No. 50 was not fair and impartial. His presence on the jury violated Ms. Maxwell’s Sixth Amendment rights and constituted structural, reversible error. This Court should vacate the
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