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673 KB
Extraction Summary
5
People
2
Organizations
0
Locations
2
Events
2
Relationships
8
Quotes
Document Information
Type:
Legal filing / appellate brief
File Size:
673 KB
Summary
This document is page 28 of a legal appellate brief (Case 22-1426) filed on July 27, 2023, arguing that Ghislaine Maxwell's conviction should be overturned due to 'Juror 50's' bias. The text contends that Juror 50 failed to disclose his own history of sexual abuse during voir dire, which later caused him to improperly identify with prosecution witnesses and influence other jurors based on his personal trauma rather than the evidence alone.
People (5)
| Name | Role | Context |
|---|---|---|
| Maxwell | Defendant/Appellant |
Subject of the legal argument regarding juror bias.
|
| Juror 50 | Juror |
Accused of actual, implied, and inferable bias due to past sexual abuse experiences and non-disclosure during voir dire.
|
| Government witnesses | Witnesses |
Individuals testifying for the prosecution whom Juror 50 identified with.
|
| Defense witnesses | Witnesses |
Individuals testifying for the defense whom Juror 50 discredited.
|
| The Court | Judiciary |
Held a view contrary to the argument presented in this document regarding the juror's impartiality.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Government |
Refers to the prosecution team/case.
|
|
| DOJ-OGR |
Source of the document (footer).
|
Relationships (2)
Identified with them through lens of own experience; bonded so profoundly he contacted one after trial.
Convinced other jurors to credit testimony of Government witnesses and discredit defense witnesses.
Key Quotes (8)
"Juror 50's Actual, Implied, and Inferable Bias Was Established."Source
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Quote #1
"Maxwell does not seek a per se rule of exclusion of victims of child abuse in sex trafficking cases"Source
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Quote #2
"it is this juror in this situation that the law would properly “cautiously incapacitate” because persons in such a situation would naturally feel prejudice."Source
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Quote #3
"Juror 50 admitted as much when he described how he identified with the Government witnesses through the lens of his own experience of child sexual abuse"Source
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Quote #4
"convinced other jurors to credit the testimony of Government witnesses and discredit defense witnesses precisely because of his unique insight about memory for child sexual assault"Source
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Quote #5
"bonded so profoundly with the Government witnesses that he felt compelled to contact one after trial"Source
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Quote #6
"Suffice to say, this was not an example of an impartial juror using his “life experiences” in the performance of his civic duty, contrary to the Court’s view."Source
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Quote #7
"But his omissions during voir dire presented the sort of "extreme situation" that would qualify for presumptive bias."Source
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Quote #8
Full Extracted Text
Complete text extracted from the document (1,605 characters)
Case 22-1426, Document 87, 07/27/2023, 3548202, Page28 of 35
D. Juror 50’s Actual, Implied, and Inferable Bias Was Established.
Maxwell does not seek a per se rule of exclusion of victims of child abuse in sex trafficking cases, although admittedly, it would be difficult to imagine how such a traumatic experience could fail to give rise to inferable bias. Certain life experiences create permanent biases. Nevertheless, it is this juror in this situation that the law would properly “cautiously incapacitate” because persons in such a situation would naturally feel prejudice. In his post-verdict interviews, Juror 50 admitted as much when he described how he identified with the Government witnesses through the lens of his own experience of child sexual abuse; convinced other jurors to credit the testimony of Government witnesses and discredit defense witnesses precisely because of his unique insight about memory for child sexual assault; and bonded so profoundly with the Government witnesses that he felt compelled to contact one after trial and to give interviews about his own experience. Suffice to say, this was not an example of an impartial juror using his “life experiences” in the performance of his civic duty, contrary to the Court’s view. A352.
Juror 50 had no such relationships to the parties, counsel, or the very crime itself. But his omissions during voir dire presented the sort of "extreme situation" that would qualify for presumptive bias. Torres at 46. The average person, victimized by sexual abuse, would be biased when he speaks about his healing
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DOJ-OGR-00021770
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