DOJ-OGR-00009895.jpg
683 KB
Extraction Summary
4
People
4
Organizations
0
Locations
1
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal filing (court document)
File Size:
683 KB
Summary
This document is page 26 of a legal filing from March 11, 2022, in the case of United States v. Ghislaine Maxwell. The text argues that the Court must conduct a broad inquiry into Juror No. 50's potential bias and intent, asserting that the juror has a history of giving false answers. It contrasts Juror No. 50 with Jurors 189 and 239, who properly disclosed details of past sexual abuse in written questionnaires, though the specific details of that abuse are redacted in this document.
People (4)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
Party arguing that Juror No. 50's intent and bias must be investigated.
|
| Juror No. 50 | Juror |
Accused of having a 'pattern and practice of giving false answers to the Court' regarding potential bias.
|
| Juror 189 | Juror |
Cited as an example of a juror who disclosed abuse details in writing (Question 48a).
|
| Juror 239 | Juror |
Cited as an example of a juror who disclosed abuse details; details redacted.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| The Court |
Responsible for questioning jurors and determining bias.
|
|
| The Government |
Opposing Ms. Maxwell's motion; accused of being disingenuous regarding voir dire requirements.
|
|
| 2d Cir. |
Cited in legal precedent (United States v. James).
|
|
| DOJ |
Department of Justice (inferred from Bates stamp DOJ-OGR).
|
Relationships (1)
Ms. Maxwell arguing Juror 50 showed bias and gave false answers.
Key Quotes (4)
"Juror No. 50 has a pattern and practice of giving false answers to the Court"Source
DOJ-OGR-00009895.jpg
Quote #1
"Ms. Maxwell is not required to accept any post-hoc assertion by him that he did not act deliberately."Source
DOJ-OGR-00009895.jpg
Quote #2
"The government disingenuously suggests that the Court "need not inquire about the details of the victim’s sexual abuse...""Source
DOJ-OGR-00009895.jpg
Quote #3
"Apparently the government has forgotten that Question 48a itself (approved of by the government) asked for details of any affirmative answer to Question 48"Source
DOJ-OGR-00009895.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,974 characters)
Case 1:20-cr-00330-PAE Document 644 Filed 03/11/22 Page 26 of 32
2. The questioning should encompass any topic on which actual bias may be based.
Moreover, the questioning should be significantly broader than proposed by the government. Although Ms. Maxwell need not prove Juror No. 50’s intent, whether he acted deliberately is “is among the ‘factors to be considered’ in the ultimate determination of bias. . . .” Greer, 285 F.3d at 173. An analysis of Juror No. 50’s intent requires consideration of the totality of the circumstances. And if only because Juror No. 50 has a pattern and practice of giving false answers to the Court, Ms. Maxwell is not required to accept any post-hoc assertion by him that he did not act deliberately. Cf. United States v. James, 609 F.2d 36, 46 (2d Cir. 1979) (“[W]hen attempting to show bias or interest, as opposed to bad reputation, the examiner is not bound to accept the witness’ answer, but is free to call additional witnesses for impeachment.”).
The government disingenuously suggests that the Court "need not inquire about the details of the victim’s sexual abuse, just as the Court did not probe such details with respect to other jurors who answered Question 48 affirmatively." Resp. at 34 n.16. Apparently the government has forgotten that Question 48a itself (approved of by the government) asked for details of any affirmative answer to Question 48, and each of the other jurors who answered 48 in the affirmative provided those details in written form when they answered Question 48a. There was thus no need for the Court to inquire the details during the live voir dire. For example, the government points to Juror 189 and notes the Court only followed up with the question whether a question concerning ability to be fair and impartial. Resp. at 36. Yet Juror 189’s answer to 48a contained the details of her alleged abuse [REDACTED].
[REDACTED]. The same with Juror 239: [REDACTED]
[REDACTED]
21
DOJ-OGR-00009895
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document