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623 KB
Extraction Summary
2
People
3
Organizations
1
Locations
2
Events
2
Relationships
6
Quotes
Document Information
Type:
Court filing / legal motion (defense reply)
File Size:
623 KB
Summary
This document is a page from a legal filing by Ghislaine Maxwell's defense team, arguing that Juror No. 50 should not be given access to a sealed questionnaire prior to a potential hearing, as it might allow him to fabricate excuses. The defense concludes that the prosecution is applying a double standard regarding juror misconduct and asserts that Maxwell's Sixth Amendment rights were violated by the juror's presence, requesting the court vacate the conviction (implied by cut-off text).
People (2)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the trial; arguing for a new trial based on juror misconduct and violation of Sixth Amendment rights.
|
| Juror No. 50 | Juror |
Accused of falsely answering voir dire questions and misconduct; requested access to a sealed questionnaire.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Government / The Prosecution |
Accused by the defense of having a 'double standard' regarding juror misconduct.
|
|
| DOJ |
Department of Justice (indicated by footer stamp DOJ-OGR).
|
|
| This Court |
United States District Court (Southern District of New York implied by case number).
|
Timeline (2 events)
2022-02-24
Locations (1)
| Location | Context |
|---|---|
|
Venue where the questionnaire is under seal and where the hearing may take place.
|
Relationships (2)
Maxwell claims Juror 50's misconduct violated her constitutional rights.
Defense claims the government is downplaying the juror's false answers because they favored the prosecution.
Key Quotes (6)
"Juror No. 50 is not entitled to discovery in advance of the hearing."Source
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Quote #1
"Providing that questionnaire will only distort the search for the truth by allowing Juror No. 50 to further refine his story and excuses."Source
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Quote #2
"The prosecution’s response is not credible because the government has the luxury of a double standard."Source
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Quote #3
"If a juror had falsely answered material voir dire questions to favor Ms. Maxwell, the government would not hesitate to prosecute the juror for contempt or perjury."Source
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Quote #4
"But all trials, perfect or not, require a fair and impartial jury. That is non-negotiable."Source
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Quote #5
"His presence on the jury violated Ms. Maxwell’s Sixth Amendment rights and constituted structural, reversible error."Source
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Quote #6
Full Extracted Text
Complete text extracted from the document (1,778 characters)
Case 1:20-cr-00330-PAE Document 616 Filed 02/24/22 Page 30 of 32
[REDACTED BLOCK]
5. Juror No. 50 is not entitled to discovery in advance of the hearing.
Finally, for all the reasons given in the new trial motion and the letters about sealing, Ms.
Maxwell maintains that Juror No. 50 should not be provided a copy of the questionnaire, which
is currently under seal in this Court. Providing that questionnaire will only distort the search for
the truth by allowing Juror No. 50 to further refine his story and excuses. Of course, if this Court
orders a hearing, Juror No. 50 will receive his questionnaire at that time. But balanced against
Ms. Maxwell’s constitutional right to a fair and impartial jury and this Court’s unflagging duty to
investigate Ms. Maxwell’s claim, Juror No. 50’s request for the questionnaire now pales in
comparison.
Maxwell maintains that Juror No. 50 should not be provided a copy of the questionnaire, which
is currently under seal in this Court. Providing that questionnaire will only distort the search for
the truth by allowing Juror No. 50 to further refine his story and excuses. Of course, if this Court
orders a hearing, Juror No. 50 will receive his questionnaire at that time. But balanced against
Ms. Maxwell’s constitutional right to a fair and impartial jury and this Court’s unflagging duty to
investigate Ms. Maxwell’s claim, Juror No. 50’s request for the questionnaire now pales in
comparison.
Conclusion
Let there be no doubt. The prosecution’s response is not credible because the government
has the luxury of a double standard. If a juror had falsely answered material voir dire questions
to favor Ms. Maxwell, the government would not hesitate to prosecute the juror for contempt or
perjury. But when, as here, a juror falsely answers voir dire questions to favor the prosecution,
the government invokes words like “finality” and “disfavor” and sighs, “well, no trial is perfect.”
has the luxury of a double standard. If a juror had falsely answered material voir dire questions
to favor Ms. Maxwell, the government would not hesitate to prosecute the juror for contempt or
perjury. But when, as here, a juror falsely answers voir dire questions to favor the prosecution,
the government invokes words like “finality” and “disfavor” and sighs, “well, no trial is perfect.”
But all trials, perfect or not, require a fair and impartial jury. That is non-negotiable. That
is the premise and fundamental guarantee of the criminal justice system, a system that was
undermined by Juror No. 50’s misconduct.
is the premise and fundamental guarantee of the criminal justice system, a system that was
undermined by Juror No. 50’s misconduct.
Juror No. 50 was not fair and impartial. His presence on the jury violated Ms. Maxwell’s
Sixth Amendment rights and constituted structural, reversible error. This Court should vacate the
Sixth Amendment rights and constituted structural, reversible error. This Court should vacate the
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DOJ-OGR-00009220
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