DOJ-OGR-00009882.jpg
716 KB
Extraction Summary
5
People
2
Organizations
0
Locations
2
Events
1
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
716 KB
Summary
This legal document argues that the government's reliance on the Tanner and Ianniello precedents is misplaced in the case of Ms. Maxwell. The author contends that unlike those cases, which dealt with conduct during deliberations, this case involves a juror (Juror No. 50) who gave false answers during voir dire—conduct outside the jury room—and therefore an evidentiary hearing is warranted. The document further notes that the juror has actively sought public attention, which is how his false answers became known.
People (5)
| Name | Role | Context |
|---|---|---|
| Tanner | Party in a legal case |
Mentioned as a legal precedent in the case Tanner, 483 U.S. at 119.
|
| Ianniello | Party in a legal case |
Mentioned as a legal precedent in the case Ianniello, 866 F.2d at 543.
|
| Ms. Maxwell | Defendant/Party in a legal case |
A party in the current case whose motion is being discussed. The government is said to concede her entitlement to an ...
|
| Juror No. 50 | Juror |
A juror in Ms. Maxwell's case who is alleged to have given false answers during voir dire and has since sought public...
|
| Moon | Party in a legal case |
Mentioned as a legal precedent in the case United States v. Moon, 718 F.2d 1210, 1234.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Supreme Court | government agency |
Mentioned in reference to its decision in the Tanner case.
|
| Second Circuit | government agency |
Mentioned for its cautionary note in the Ianniello case and its ruling in United States v. Moon.
|
Timeline (2 events)
Voir dire process during which Juror No. 50 allegedly falsely answered questions to gain a seat on the jury.
Ms. Maxwell's motion regarding Juror No. 50's conduct, leading to a discussion about an evidentiary hearing.
Ms. Maxwell
the government
Relationships (1)
Ms. Maxwell's motion is based on the allegation that Juror No. 50 gave false answers during voir dire for her trial.
Key Quotes (2)
"shielding jury deliberations from public scrutiny"Source
— Supreme Court (in Tanner)
(Described as the motivation for the Supreme Court's decision in the Tanner case.)
DOJ-OGR-00009882.jpg
Quote #1
"a post-trial jury hearing must be held when a party comes forward with ‘clear, strong, substantial and incontrovertible evidence . . . that a specific, non-speculative impropriety has occurred.’"Source
— Second Circuit (in Ianniello, quoting Moon)
(Quoted to explain the standard for ordering a post-trial evidentiary hearing regarding jury conduct.)
DOJ-OGR-00009882.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,130 characters)
Case 1:20-cr-00330-PAE Document 644 Filed 03/11/22 Page 13 of 32
The government’s invocation of Tanner and Ianniello is strikingly disingenuous. Both cases involved alleged conduct during trial and, crucially, during deliberations. The interest in “shielding jury deliberations from public scrutiny” is what motivated the Supreme Court’s decision in Tanner, 483 U.S. at 119, and the Second Circuit’s cautionary note in Ianniello, 866 F.2d at 543.
In this case, by contrast, there is at least one juror who falsely answered voir dire questions to gain a seat on the jury, conduct that occurred outside the jury room. The reluctance of courts to second-guess jury deliberations by inquiring into how the jury reached its decision simply has no relevance here, and neither do Tanner or Ianniello.
In fact, the government’s reliance on Ianniello is doubly wrong, because the Second Circuit there set aside any reluctance it might have had to question the conduct of deliberations by ordering the defendant’s requested evidentiary hearing. As the Court explained, “a post-trial jury hearing must be held when a party comes forward with ‘clear, strong, substantial and incontrovertible evidence . . . that a specific, non-speculative impropriety has occurred.’” Ianniello, 866 F.2d at 543 (quoting United States v. Moon, 718 F.2d 1210, 1234 (2d Cir. 1983)).⁴ Here, of course, the government concedes Ms. Maxwell’s entitlement to an evidentiary hearing.
The government cannot with a straight face claim that Ms. Maxwell’s motion risks exposing Juror No. 50 to harassment and intimidation. Let’s be clear. The only reason Ms. Maxwell knows of Juror No. 50’s false answers during voir dire is that Juror No. 50 has sought out the limelight. He has sat for several interviews with journalists, he has allowed himself to be videotaped, he has Tweeted and publicized himself on social media, and he has even participated
⁴ To be clear, this standard does not apply to Ms. Maxwell’s claim; it applies when a new trial motion alleges misconduct during deliberations. Ianniello, 866 F.3d at 543; Moon, 718 F.3d at 1234.
8
DOJ-OGR-00009882
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document