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Extraction Summary

4
People
3
Organizations
0
Locations
2
Events
1
Relationships
4
Quotes

Document Information

Type: Court filing (legal memorandum/motion)
File Size: 554 KB
Summary

This is a page from a legal filing in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), dated February 24, 2022. The document argues that Juror No. 50 falsely answered questions during jury selection (voir dire) and requests subpoenas for the juror's emails with alleged victims, witnesses, or other jurors.

People (4)

Name Role Context
Ms. Maxwell Defendant
Argues that Juror No. 50 falsely answered questions and requests subpoenas for discovery.
Juror No. 50 Juror
Accused of falsely answering material questions during voir dire; subject of requested subpoenas.
Russell Litigant
Mentioned in case citation 'Russell v. United States'.
French Litigant
Mentioned in case citation 'United States v. French'.

Organizations (3)

Name Type Context
United States District Court
The court handling Case 1:20-cr-00330-PAE.
DOJ
Department of Justice (referenced in footer stamp DOJ-OGR-00009056).
1st Cir.
First Circuit Court of Appeals (cited in legal precedence).

Timeline (2 events)

2022-02-24
Filing of Document 613 in Case 1:20-cr-00330-PAE
Court
Ms. Maxwell Court
Prior to 2022-02-24
Voir dire (Jury Selection)
Court

Relationships (1)

Ms. Maxwell Legal Adversary Juror No. 50
Maxwell accusing Juror of misconduct and requesting subpoenas against them.

Key Quotes (4)

"Ms. Maxwell does not believe an evidentiary hearing is required because the undisputed evidence shows (1) that Juror No. 50 falsely answered a material question during voir dire"
Source
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Quote #1
"If this Court disagrees, however, a formal evidentiary hearing is appropriate."
Source
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Quote #2
"an unflagging duty falls to the district court to investigate the claim."
Source
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Quote #3
"[A] formal evidentiary hearing [is] the gold standard for an inquiry into alleged juror misconduct."
Source
DOJ-OGR-00009056.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (1,395 characters)

Case 1:20-cr-00330-PAE Document 613 Filed 02/24/22 Page 55 of 66
experiences, he would have been excused, if not for cause, then as a defense peremptory
strike.
II. The scope of any evidentiary hearing
Ms. Maxwell does not believe an evidentiary hearing is required because the
undisputed evidence shows (1) that Juror No. 50 falsely answered a material question
during voir dire and (2) that, had he answered truthfully, he would have been subject to a
challenge for cause. If this Court disagrees, however, a formal evidentiary hearing is
appropriate.
When, as here, there is a plausible claim of juror misconduct, “an unflagging duty
falls to the district court to investigate the claim.” United States v. French, 904 F.3d 111,
117 (1st Cir. 2018) (quotation omitted). “[A] formal evidentiary hearing [is] the gold
standard for an inquiry into alleged juror misconduct.” United States v. French, 977 F.3d
114, 122 (1st Cir. 2020), cert. denied, 141 S. Ct. 2601 (2021), cert. denied sub nom.
Russell v. United States, 141 S. Ct. 2601 (2021).
A. Pre-hearing discovery
Ms. Maxwell requests that the Court authorize subpoenas to:
1. Juror No. 50 to produce:
a. Emails or other written communications between Juror No. 50 and any
alleged victim or witness in this case;
b. Emails or other written communications between Juror No. 50 and any
other juror in this case;
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DOJ-OGR-00009056

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