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618 KB

Extraction Summary

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

Document Information

Type: Court filing / legal memorandum (post-trial motion response)
File Size: 618 KB
Summary

This document is page 30 of a court filing (Doc 643) from the US v. Ghislaine Maxwell case, filed on March 11, 2022. It is likely a government response arguing against a retrial, specifically refuting the defendant's claims that 'Juror 50' lied about social media accounts or held implied bias. The text distinguishes the current situation from the 'Daugerdas' precedent and asserts that even if the juror had answered truthfully about social media, they would not have been struck for cause.

People (4)

Name Role Context
Juror 50 Juror
Subject of a defense motion alleging bias and dishonesty regarding social media usage.
Juror 55 Juror
A juror dismissed for cause, used by the defense as a comparison to Juror 50.
Judge Pauley Judge
Judge in the referenced 'Daugerdas' case precedent.
Defendant Defendant
The party (Ghislaine Maxwell, based on case number) arguing for implied bias.

Organizations (2)

Name Type Context
Department of Justice (DOJ)
Indicated by the Bates stamp 'DOJ-OGR'.
US District Court
Implied by the case filing header.

Timeline (2 events)

2022-03-11
Filing of Document 643 in Case 1:20-cr-00330-PAE
Court Record
Unknown
Voir Dire
Courtroom
Juror 50 Court

Relationships (2)

Defendant Legal Adversary Juror 50
Defendant alleges that Juror 50 has repeatedly lied.
Juror 50 Comparison Juror 55
The record also does not support the defendant’s attempt to compare Juror 50 to Juror 55

Key Quotes (3)

"the juror 'created a totally fictitious persona in her drive to get on the jury' and was 'a pathological liar who does not know the difference between truth and lie.'"
Source
DOJ-OGR-00009828.jpg
Quote #1
"There is nothing in the record about Juror 50’s use of social media accounts that would have supported a challenge for cause at voir dire."
Source
DOJ-OGR-00009828.jpg
Quote #2
"In sum, the defendant has failed to establish implied bias."
Source
DOJ-OGR-00009828.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (1,745 characters)

Case 1:20-cr-00330-PAE Document 643 Filed 03/11/22 Page 30 of 49
serve as jurors in such cases, the defendant would have cited case law that actually supports that
proposition.
Finally, the defendant also argues that bias should be implied because she alleges that Juror
50 has repeatedly lied. (Def. Mem. at 35-36 (citing Daugerdas, 867 F. Supp. 2d at 472)). As
discussed in greater detail above, the record does not support this, and, as a result, this is a far cry
from the extreme circumstances in Daugerdas, where Judge Pauley concluded after a hearing that
the juror “created a totally fictitious persona in her drive to get on the jury” and was “a pathological
liar who does not know the difference between truth and lie.” Id. at 473, 475.
The record also does not support the defendant’s attempt to compare Juror 50 to Juror 55,
who was dismissed for cause [REDACTED]
[REDACTED]
[REDACTED] As noted above, there is no evidence that Juror 50 lied about his social media
accounts. Moreover, the defendant’s analogy misunderstands the nature of the current inquiry, in
which the Court must consider the hypothetical question whether, if the juror had truthfully
answered the relevant question, the Court would have struck him for cause. See Stewart, 433 F.3d
at 304. [REDACTED] But here, in
a post-verdict posture, if the Court were to find that Juror 50 intentionally lied about using social
media accounts, the question would be whether the Court would have struck him if he had
truthfully answered that question. There is nothing in the record about Juror 50’s use of social
media accounts that would have supported a challenge for cause at voir dire.
In sum, the defendant has failed to establish implied bias.
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DOJ-OGR-00009828

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