DOJ-OGR-00009165.jpg
712 KB
Extraction Summary
3
People
4
Organizations
1
Locations
1
Events
2
Relationships
4
Quotes
Document Information
Type:
Court filing / legal brief (government response)
File Size:
712 KB
Summary
This document is page 46 of a legal filing from the Ghislaine Maxwell case (1:20-cr-00330-PAE), filed on February 24, 2022. The Government argues that 'Juror 50' should be allowed to review his jury questionnaire before any potential hearing to consult with counsel regarding his Fifth Amendment rights. The text notes that Juror 50 does not recall answering questions about sexual assault and discusses procedural arguments regarding subpoenas and the scope of the inquiry.
People (3)
| Name | Role | Context |
|---|---|---|
| Juror 50 | Juror / Witness |
Subject of a potential evidentiary hearing regarding juror misconduct; requested access to his questionnaire; potenti...
|
| The Defendant | Defendant |
Refers to Ghislaine Maxwell (based on case number 1:20-cr-00330); opposing the provision of the questionnaire to Juro...
|
| Counsel for Juror 50 | Attorney |
Legal representation Juror 50 needs to consult regarding the Fifth Amendment.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| The Government |
Prosecution (DOJ); arguing that Juror 50 should see his questionnaire before the hearing.
|
|
| The Court |
Judicial body overseeing the hearing and deciding on subpoenas.
|
|
| S.D.N.Y. |
Southern District of New York (referenced in case citation).
|
|
| City of Almaty |
Plaintiff in a cited legal precedent.
|
Locations (1)
| Location | Context |
|---|---|
|
Jurisdiction of the cited case.
|
Relationships (2)
Debating whether Juror 50 should receive his questionnaire in advance.
Text mentions Juror 50 needing to speak with his counsel regarding Fifth Amendment rights.
Key Quotes (4)
"Juror 50 should have access to his own questionnaire in advance of any such hearing so that he can speak with his counsel and assess whether he plans to invoke his rights under the Fifth Amendment."Source
DOJ-OGR-00009165.jpg
Quote #1
"That endeavor is not furthered by surprising Juror 50 on the stand with a document he does not seem to recall with specificity."Source
DOJ-OGR-00009165.jpg
Quote #2
"Juror 50 'does not recall answering questions [in the questionnaire] regarding his prior experience with sexual assault'"Source
DOJ-OGR-00009165.jpg
Quote #3
"The Government agrees with the defendant that Juror 50 need not be permitted to intervene or be heard on the scope of the Court’s inquiry"Source
DOJ-OGR-00009165.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,123 characters)
Case 1:20-cr-00330-PAE Document 615 Filed 02/24/22 Page 46 of 49
Moreover, there can be no real concern, as the defendant claims, that providing Juror 50
with his questionnaire will “color” Juror 50’s testimony and interfere with the integrity of a
hearing. (Def. Mem. at 53). Should the Court decide to conduct a limited hearing, as the
Government has proposed, the Court will undoubtedly ask Juror 50 about his questionnaire. Juror
50 should have access to his own questionnaire in advance of any such hearing so that he can speak
with his counsel and assess whether he plans to invoke his rights under the Fifth Amendment.
More broadly speaking, “[t]he object of the proceeding is to permit the truth to be discovered with
the least possible harm to other interests.” Gagnon, 282 F. App’x at 40. That endeavor is not
furthered by surprising Juror 50 on the stand with a document he does not seem to recall with
specificity. See Juror 50 Mem. at 4 (stating that Juror 50 “does not recall answering questions [in
the questionnaire] regarding his prior experience with sexual assault”). To deny Juror 50 access
to his own document means, practically speaking, that after being shown the questionnaire and
asked questions about the document at a hearing, Juror 50 will need to speak with his counsel,
assuredly delaying the hearing.
with his questionnaire will “color” Juror 50’s testimony and interfere with the integrity of a
hearing. (Def. Mem. at 53). Should the Court decide to conduct a limited hearing, as the
Government has proposed, the Court will undoubtedly ask Juror 50 about his questionnaire. Juror
50 should have access to his own questionnaire in advance of any such hearing so that he can speak
with his counsel and assess whether he plans to invoke his rights under the Fifth Amendment.
More broadly speaking, “[t]he object of the proceeding is to permit the truth to be discovered with
the least possible harm to other interests.” Gagnon, 282 F. App’x at 40. That endeavor is not
furthered by surprising Juror 50 on the stand with a document he does not seem to recall with
specificity. See Juror 50 Mem. at 4 (stating that Juror 50 “does not recall answering questions [in
the questionnaire] regarding his prior experience with sexual assault”). To deny Juror 50 access
to his own document means, practically speaking, that after being shown the questionnaire and
asked questions about the document at a hearing, Juror 50 will need to speak with his counsel,
assuredly delaying the hearing.
To the extent Juror 50’s motion seeks leave to submit briefing on the merits of this inquiry,
the Government agrees with the defendant that Juror 50 need not be permitted to intervene or be
heard on the scope of the Court’s inquiry, at least not at this juncture. The parties are well situated
to brief the appropriate scope of any hearing without intervention from the witness at that hearing.
However, if the Court does authorize the subpoenas compelling production of Juror 50’s
communications and other information—though it should not, for the reasons set forth above—
Juror 50 should have an opportunity to move to quash those subpoenas. See , e.g., City of Almaty,
Kazakhstan v. Ablyazov, No. 1:15 Civ. 05345 (AJN) (KHP), 2020 WL 1130670, at *1 (S.D.N.Y.
the Government agrees with the defendant that Juror 50 need not be permitted to intervene or be
heard on the scope of the Court’s inquiry, at least not at this juncture. The parties are well situated
to brief the appropriate scope of any hearing without intervention from the witness at that hearing.
However, if the Court does authorize the subpoenas compelling production of Juror 50’s
communications and other information—though it should not, for the reasons set forth above—
Juror 50 should have an opportunity to move to quash those subpoenas. See , e.g., City of Almaty,
Kazakhstan v. Ablyazov, No. 1:15 Civ. 05345 (AJN) (KHP), 2020 WL 1130670, at *1 (S.D.N.Y.
44
DOJ-OGR-00009165
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document