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619 KB

Extraction Summary

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

Document Information

Type: Court filing (proposed voir dire questions and jury instructions)
File Size: 619 KB
Summary

This document is a page from a legal filing (Case 1:20-cr-00330-PAE) dated October 22, 2021, containing proposed voir dire questions and jury instructions. It specifically highlights disputes between the Government and the Defense regarding whether potential jurors should be asked live questions about their knowledge of or dealings with Jeffrey Epstein and Ghislaine Maxwell. The text includes standard admonitions to jurors not to discuss the case and to report any outside communication attempts.

People (4)

Name Role Context
Jeffrey Epstein Associate of Defendant
Subject of proposed voir dire question (o) asking jurors if they knew or had dealings with him.
Ms. Maxwell Defendant
Subject of proposed voir dire question (p) asking jurors if they knew or had dealings with her. Also referred to as '...
Juror Target Audience
Individuals being questioned and instructed.
Deputy Clerk Court Official
Person to whom jurors should report attempts by others to communicate about the case.

Organizations (3)

Name Type Context
Government
Prosecution team objecting to specific voir dire questions.
DOJ
Department of Justice (indicated by Bates stamp DOJ-OGR).
Court
Judicial body overseeing the trial.

Timeline (2 events)

2021-10-22
Filing of document 367-1 in Case 1:20-cr-00330-PAE
Court
Government Defendant
Future (relative to doc)
Impaneling of the Jury
Courtroom
Jurors Court Attorneys

Locations (2)

Location Context
Mentioned in instruction 66 regarding where communications might occur.
Mentioned in instruction 66.

Relationships (1)

Jeffrey Epstein Co-associated in legal questioning Ms. Maxwell
Questions (o) and (p) mirror each other, asking jurors about their knowledge of both individuals.

Key Quotes (4)

"Do you know, or have you had any dealings, personal or business, with Jeffrey Epstein, or with any of his relatives or friends?"
Source
DOJ-OGR-00005373.jpg
Quote #1
"Do you know, or have you had any dealings, personal or business, with Ms. Maxwell, or with any of her relatives or friends?"
Source
DOJ-OGR-00005373.jpg
Quote #2
"The Government objects to Questions 65(o) and (p) proposed by the defendant on the grounds that the questions are duplicative"
Source
DOJ-OGR-00005373.jpg
Quote #3
"asking the questions live when the jurors reactions, hesitations, explanations can be explored by the Court and observed by the parties will aid in the selection of an impartial and fair jury."
Source
DOJ-OGR-00005373.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (2,679 characters)

Case 1:20-cr-00330-PAE Document 367-1 Filed 10/22/21 Page 16 of 17
(i) the same employment information with respect to the juror’s significant other and any working children or member of the juror’s household;
(j) the newspapers or magazines that the juror typically reads and how often;
(k) the websites that the juror reads and/or posts comments or information on;
(l) the television shows that the juror typically watches and or radio programs the juror regularly listens to;
(m)the juror’s hobbies and leisure-time activities; and
(n) whether the juror is a member of any clubs or organizations to which you contribute your time or money.
(o) Do you know, or have you had any dealings, personal or business, with Jeffrey Epstein, or with any of his relatives or friends? [If Yes/Unsure, question privately]
(p) Do you know, or have you had any dealings, personal or business, with Ms. Maxwell, or with any of her relatives or friends? [If Yes/Unsure, question privately]
Requested Instruction Following Impaneling of the Jury
65. From this point until the time when you retire to deliberate your verdict, it is your duty not to discuss this case, and not to remain in the presence of other persons who may be discussing this case. The rule about not discussing the case with others includes discussions even with members of your own family, and your friends.
66. If at any time during the course of the trial, any person attempts to talk to you or to communicate with you about this case, either in or out of the courthouse, you should immediately report such an attempt to me through my deputy clerk. In this regard, let me explain to you that the attorneys and defendant in a case are not supposed to talk to jurors, not even to offer a friendly greeting. So, if you happen to see any of them outside this courtroom, they will, and should, ignore you. Please do not take offense. They will be acting properly by doing so.
[Sidebar Comments]
Commented [A20]: GOVERNMENT OBJECTION: The Government objects to Questions 65(o) and (p) proposed by the defendant on the grounds that the questions are duplicative of questions included in the proposed questionnaire. Jurors should be asked follow-up questions during voir dire as necessary, but need not be asked the same questions again.
Commented [A21R20]: DEFENDANT RESPONSE: The defense responds that (a) the Court has not yet ruled on the admissibility of the questions on the questionnaire, and (b) asking the questions live when the jurors reactions, hesitations, explanations can be explored by the Court and observed by the parties will aid in the selection of an impartial and fair jury.
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