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Extraction Summary
5
People
3
Organizations
1
Locations
2
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal filing (motion/brief)
File Size:
774 KB
Summary
This is page 4 of a legal filing (Document 649) from the Law Offices of Bobbi C. Sternheim, filed on March 15, 2022, in the case of United States v. Maxwell. The text argues that 'Juror 50' demonstrated bias by lying on a questionnaire about his own history of sexual abuse, which the defense argues closely paralleled the abuse described by victims at the trial. The filing highlights that the juror was abused by a familiar person (his stepbrother), mirroring the allegations against Epstein and Maxwell, and argues he would have been struck for cause had he been honest.
People (5)
| Name | Role | Context |
|---|---|---|
| Juror 50 | Juror |
Accused of dishonesty and bias regarding past sexual abuse history during voir dire.
|
| Ms. Maxwell | Defendant |
Ghislaine Maxwell; the document argues she was denied the opportunity to question the juror properly.
|
| Epstein | Associate |
Mentioned in comparison to the juror's abuser; the accusers described relationships between their families and Epstei...
|
| Bobbi C. Sternheim | Attorney |
Name appears in the letterhead 'Law Offices of Bobbi C. Sternheim'.
|
| Juror 50's stepbrother | Abuser |
Identified as the person who abused Juror 50.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim |
Legal firm filing the document.
|
|
| United States District Court |
Implied by case citation format (S.D.N.Y.).
|
|
| Department of Justice (DOJ) |
Implied by the footer stamp 'DOJ-OGR'.
|
Timeline (2 events)
Locations (1)
| Location | Context |
|---|---|
|
Southern District of New York (cited in legal precedent, implied jurisdiction).
|
Relationships (2)
He was abused by someone familiar to him, his stepbrother, who was part of his life
accusers described the relationship between their families and Epstein and Ms. Maxwell
Key Quotes (3)
"In determining whether Juror 50 was biased, the Court should consider several factors, including '[1] the similarity between the juror’s experiences and important facts presented at trial, [2] the scope and severity of the juror’s dishonesty, and [3] the juror’s motive for lying.'"Source
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Quote #1
"Like the four accusers, Juror 50 (i) was sexually abused as a minor, (ii) was abused on multiple occasions over the course of several years, and (iii) delayed reporting the abuse."Source
DOJ-OGR-00010310.jpg
Quote #2
"He was abused by someone familiar to him, his stepbrother, who was part of his life (Tr. 8-9), just as the four accusers described the relationship between their families and Epstein and Ms. Maxwell."Source
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,316 characters)
Case 1:20-cr-00330-PAE Document 649 Filed 03/15/22 Page 4 of 12
LAW OFFICES OF BOBBI C. STERNHEIM
LAW OFFICES OF BOBBI C. STERNHEIM
him.” United States v. Daugerdas, 867 F. Supp. 2d 445, 470 (S.D.N.Y. 2012) (quoting
McDonough, 464 U.S. at 554). Challenges for cause can be based on implied bias, inferable
bias, or actual bias. See United States v. Torres, 128 F.3d 38, 43 (2d Cir. 1997). In determining
whether Juror 50 was biased, the Court should consider several factors, including “[1] the
similarity between the juror’s experiences and important facts presented at trial, [2] the scope
and severity of the juror’s dishonesty, and [3] the juror’s motive for lying.” See Sampson v.
United States, 724 F.3d 150, 166 (1st Cir. 2013) (citations omitted). The record developed at the
Hearing strengthened the already compelling evidence of Juror 50’s bias and established that,
had he answered the questionnaire honestly, he would have been struck for cause.
McDonough, 464 U.S. at 554). Challenges for cause can be based on implied bias, inferable
bias, or actual bias. See United States v. Torres, 128 F.3d 38, 43 (2d Cir. 1997). In determining
whether Juror 50 was biased, the Court should consider several factors, including “[1] the
similarity between the juror’s experiences and important facts presented at trial, [2] the scope
and severity of the juror’s dishonesty, and [3] the juror’s motive for lying.” See Sampson v.
United States, 724 F.3d 150, 166 (1st Cir. 2013) (citations omitted). The record developed at the
Hearing strengthened the already compelling evidence of Juror 50’s bias and established that,
had he answered the questionnaire honestly, he would have been struck for cause.
A. The Similarity Between Juror 50’s Sexual Abuse and the Witnesses’ Sexual
Abuse, As Well As His Post-Trial Conduct, Establish Bias.
Abuse, As Well As His Post-Trial Conduct, Establish Bias.
At the hearing, Juror 50 disclosed the facts of his sexual abuse, which significantly
paralleled the abuse described by the government’s four key victim witnesses at trial. Jury 50
had already disclosed some of these facts in his post-trial press interviews. But the opportunity
to question Juror 50 further about the circumstances of his abuse at the Hearing—an opportunity
that Ms. Maxwell was denied at voir dire because of his false answers to the questionnaire—
revealed even more striking similarities to the abuse described by the four victim witnesses at
trial. Like the four accusers, Juror 50 (i) was sexually abused as a minor, (ii) was abused on
multiple occasions over the course of several years, and (iii) delayed reporting the abuse. (Tr. 8-
9). Like the four accusers, Juror 50 was abused by two people who were friends and who each
participated in the abuse. (Tr. 8-9). Furthermore, Juror 50 was not abused by a stranger or
sexually assaulted by someone he did not know. He was abused by someone familiar to him, his
stepbrother, who was part of his life (Tr. 8-9), just as the four accusers described the relationship
between their families and Epstein and Ms. Maxwell. These similarities are significant and
paralleled the abuse described by the government’s four key victim witnesses at trial. Jury 50
had already disclosed some of these facts in his post-trial press interviews. But the opportunity
to question Juror 50 further about the circumstances of his abuse at the Hearing—an opportunity
that Ms. Maxwell was denied at voir dire because of his false answers to the questionnaire—
revealed even more striking similarities to the abuse described by the four victim witnesses at
trial. Like the four accusers, Juror 50 (i) was sexually abused as a minor, (ii) was abused on
multiple occasions over the course of several years, and (iii) delayed reporting the abuse. (Tr. 8-
9). Like the four accusers, Juror 50 was abused by two people who were friends and who each
participated in the abuse. (Tr. 8-9). Furthermore, Juror 50 was not abused by a stranger or
sexually assaulted by someone he did not know. He was abused by someone familiar to him, his
stepbrother, who was part of his life (Tr. 8-9), just as the four accusers described the relationship
between their families and Epstein and Ms. Maxwell. These similarities are significant and
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DOJ-OGR-00010310
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