DOJ-OGR-00009161.jpg
704 KB
Extraction Summary
6
People
4
Organizations
2
Locations
2
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal document
File Size:
704 KB
Summary
This legal document argues that the court should deny the defendant's request for a post-verdict hearing and 'pre-hearing discovery' concerning juror conduct. The argument is based on legal precedent, stating that the defendant's evidence—a single anonymous sentence from a newspaper article—is inadmissible hearsay and does not meet the required standard of 'concrete allegations.' The document cites several cases to support the position that courts routinely deny such inquiries to protect the finality of verdicts and avoid the dangers of post-verdict juror scrutiny.
People (6)
| Name | Role | Context |
|---|---|---|
| Baker |
Cited in the case 'Baker, 899 F.3d at 130' for the standard required for allegations of juror impropriety.
|
|
| Sattar | Defendant |
Cited in the case 'United States v. Sattar, 395 F. Supp. 2d 66, 77 (S.D.N.Y. 2005)' as an example of courts declining...
|
| Stewart | Defendant |
Cited in the case 'United States v. Stewart, 590 F.3d 93 (2d Cir. 2009)' and 'Stewart, 317 F. Supp. 2d at 443' as an ...
|
| Daniels | Petitioner/Plaintiff |
Cited in the case 'Daniels v. Hollins, No. CV-02-4495FBLB, 2006 WL 47412, at *8 (E.D.N.Y. Jan. 9, 2006)' as an exampl...
|
| Hollins | Respondent/Defendant |
Cited in the case 'Daniels v. Hollins, No. CV-02-4495FBLB, 2006 WL 47412, at *8 (E.D.N.Y. Jan. 9, 2006)' as an exampl...
|
| Menendez | Defendant |
Cited in the case 'United States v. Menendez, 440 F. App’x 906, 911-12 (11th Cir. 2011)' as an example of courts decl...
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Schering Corp. | company |
Party in the cited case 'Schering Corp. v. Pfizer Inc., 189 F.3d 218, 232 (2d Cir. 1999)'.
|
| Pfizer Inc. | company |
Party in the cited case 'Schering Corp. v. Pfizer Inc., 189 F.3d 218, 232 (2d Cir. 1999)'.
|
| United States | government agency |
Party in the cited cases 'United States v. Sattar', 'United States v. Stewart', and 'United States v. Menendez'.
|
| DOJ | government agency |
Appears in the footer as part of a document identifier 'DOJ-OGR-00009161'.
|
Relationships (1)
defendant
→
legal
→
Court
The defendant is making requests and motions to the Court, which the author of this document argues the Court should deny.
Key Quotes (4)
"concrete allegations of inappropriate conduct that constitute competent and relevant evidence."Source
— Court in Baker case
(Describing the standard required to warrant a post-verdict hearing into jurors' conduct.)
DOJ-OGR-00009161.jpg
Quote #1
"four classes of risk peculiar to this kind of evidence: those of (1) insincerity, (2) faulty perception, (3) faulty memory and (4) faulty narration"Source
— Court in Schering Corp. v. Pfizer Inc. case
(Describing the risks inherent in relying on hearsay information, such as a report from a newspaper article.)
DOJ-OGR-00009161.jpg
Quote #2
"to permit an inquiry based on such scant evidence in a case that continues to receive an unprecedented level of publicity would do serious damage to the policies that justify limitations on postverdict juror scrutiny."Source
— Court in Stewart case
(Explaining the rationale for denying post-verdict inquiries based on weak evidence, especially in high-publicity cases.)
DOJ-OGR-00009161.jpg
Quote #3
"evil consequences"Source
— unspecified court
(Used to describe the negative outcomes of post-verdict juror inquiries.)
DOJ-OGR-00009161.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,082 characters)
Case 1:20-cr-00330-PAE Document 615 Filed 02/24/22 Page 42 of 49
first instance, it held that the district court’s decision not to do so was within its broad discretion. Id. at 306.
As the foregoing cases reflect, given the dangers of post-verdict hearings into jurors’ conduct, to warrant a hearing, allegations of impropriety must be “concrete allegations of inappropriate conduct that constitute competent and relevant evidence.” Baker, 899 F.3d at 130 (quotation omitted). A single, anonymous sentence found in a newspaper article does not meet that standard. Such a report is classic hearsay and suffers from the risks inherent on relying on such information. See Schering Corp. v. Pfizer Inc., 189 F.3d 218, 232 (2d Cir. 1999) (describing the “four classes of risk peculiar to this kind of evidence: those of (1) insincerity, (2) faulty perception, (3) faulty memory and (4) faulty narration”). As such, in the foregoing cases and numerous others, courts have routinely declined to grant evidentiary hearings based solely on hearsay statements. See also, e.g., United States v. Sattar, 395 F. Supp. 2d 66, 77 (S.D.N.Y. 2005), aff’d sub nom. United States v. Stewart, 590 F.3d 93 (2d Cir. 2009); Daniels v. Hollins, No. CV-02-4495FBLB, 2006 WL 47412, at *8 (E.D.N.Y. Jan. 9, 2006); United States v. Menendez, 440 F. App’x 906, 911-12 (11th Cir. 2011). As one court observed, “to permit an inquiry based on such scant evidence in a case that continues to receive an unprecedented level of publicity would do serious damage to the policies that justify limitations on postverdict juror scrutiny.” Stewart, 317 F. Supp. 2d at 443. So too here.
The Court should deny the defendant’s request to expand the hearing to call every juror merely to inquire into a single anonymous statement in a newspaper article.
4. The Defendant’s “Discovery” Request Should Be Denied
The Court should deny the defendant’s motion for “pre-hearing discovery” in its entirety. Given the “evil consequences” of post-verdict juror inquiries, courts may not permit such inquiries
40
DOJ-OGR-00009161
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document