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537 KB

Extraction Summary

4
People
3
Organizations
3
Locations
2
Events
1
Relationships
3
Quotes

Document Information

Type: Legal document
File Size: 537 KB
Summary

This document is page 15 of a court filing from October 22, 2021, which lists proposed questions for potential jurors in a criminal case. A comment from the defense argues that juror background questions should be handled through a written questionnaire rather than live questioning (voir dire). The defense supports this by citing precedent from high-profile cases involving Elizabeth Holmes, Robert Kelly, and Keith Rainier, and notes that a verdict in another case was overturned due to jury deceit, highlighting the need for thorough vetting.

People (4)

Name Role Context
Elizabeth Holmes Defendant
Mentioned as the defendant in a cited case, United States v. Elizabeth Holmes (Theranos), used as an example of a hig...
Robert Kelly Defendant
Mentioned as the defendant in a cited case, United States v. Robert Kelly, used as an example of a high-profile feder...
Keith Rainier Defendant
Mentioned as the defendant in a cited case, United States v. Keith Rainier (Nxvim), used as an example of a high-prof...
Dangerdas Defendant
Mentioned as the defendant in a cited case, United States v. Dangerdas, where a verdict was overturned due to jury de...

Organizations (3)

Name Type Context
Theranos company
Mentioned in the citation for the United States v. Elizabeth Holmes case.
Nxvim organization
Mentioned in the citation for the United States v. Keith Rainier case.
United States Government government agency
Referred to as "The Government" which objects to the defense's proposal, and is the plaintiff in all cited legal case...

Timeline (2 events)

2012
The verdict in the United States v. Dangerdas trial, a long financial fraud trial, was overturned due to jury deceit.
SDNY
United States Dangerdas
2021-10-22
Document 367-1 was filed in case 1:20-cr-00330-PAE, containing proposed questions for jury selection.
Court
DEFENDANT Government

Locations (3)

Location Context
The location of the United States v. Elizabeth Holmes case, cited as (N.D. Cal.).
The location of the United States v. Robert Kelly and United States v. Keith Rainier cases, cited as (EDNY).
The location of the United States v. Dangerdas case and a financial fraud trial mentioned in the comment, cited as (S...

Relationships (1)

DEFENDANT adversarial Government
The document states the defense makes a proposal and "The Government objects," indicating they are opposing parties in a legal matter.

Key Quotes (3)

"The defense proposes that these questions should be more appropriately asked in the questionnaire rather than voir dire."
Source
— DEFENDANT (A comment in the document outlining the defense's position on how to handle juror background questions.)
DOJ-OGR-00005372.jpg
Quote #1
"In addition to saving immense time, it provides a good-faith foundation for conducting research on the jurors to confirm truthfulness and/or uncover bias."
Source
— DEFENDANT (The defense's justification for using a written questionnaire for juror background information.)
DOJ-OGR-00005372.jpg
Quote #2
"The Government objects but it was the Government, in the most recent high-profile federal cases, who included the very same background information questions in the written questionnaire."
Source
— DEFENDANT (The defense's counter-argument to the Government's objection, pointing out the Government's own past practices.)
DOJ-OGR-00005372.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (2,314 characters)

Case 1:20-cr-00330-PAE Document 367-1 Filed 10/22/21 Page 15 of 17
58. Do you have any difficulty with your sight or hearing that could affect your ability to see or hear what happens during the trial?
59. Do you have any difficulty understanding, reading, or speaking the English language?
60. Have you or has anyone close to you ever been charged with a crime?
61. Have you or anyone close to you ever been accused of sexual assault or sexual harassment?
62. Have you or has anyone close to you ever been the victim of a crime? [If Yes/Unsure question privately.]
63. Have you or has anyone close to you ever been the victim of a sexual crime? [If Yes/Unsure question privately.]
Jurors’ Background
64. The parties respectfully request that the Court ask each juror to state the following information:
(a) the juror’s age;
(b) the juror’s family status (including whether the juror has any children and, if so, ages of the children);
(c) the juror’s current town of residence and length of time at the residence;
(d) the juror’s county of residence during the past ten years;
(e) the educational background of the juror, including the highest degree obtained;
(f) the juror’s occupation;
(g) the name and general location of the juror’s employer, and the period of employment with that employer;
(h) the same information concerning other employment within the last five years;
Commented [A19]: DEFENDANT. The defense proposes that these questions should be more appropriately asked in the questionnaire rather than voir dire. See Joint Proposed Jury Questionnaire. The Government objects but it was the Government, in the most recent high-profile federal cases, who included the very same background information questions in the written questionnaire. See United States v. Elizabeth Holmes (Theranos), 18 Cr. 258 (EDJ) (N.D. Cal.); United States v. Robert Kelly, 19 Cr. 286 (AMD) (EDNY); United States v. Keith Rainier (Nxvim), 18 Cr. 204 (NGG) (EDNY).
In addition to saving immense time, it provides a good-faith foundation for conducting research on the jurors to confirm truthfulness and/or uncover bias. In addition, the verdict in one of longest financial fraud trials in SDNY was overturned due to jury deceit. See United States v. Dangerdas, 867 F.Supp.2d 445 (SDNY 2012).
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DOJ-OGR-000005372

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