DOJ-OGR-00009752.jpg

669 KB

Extraction Summary

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

Document Information

Type: Court filing / legal brief (government response)
File Size: 669 KB
Summary

This page from a court filing (Case 1:20-cr-00330-PAE, likely United States v. Ghislaine Maxwell) argues against providing discovery materials (specifically a questionnaire) to 'Juror No. 50.' The prosecution contends that releasing this information would allow the juror to manipulate their testimony and argues that the juror lacks standing, citing various legal precedents. The document suggests Juror No. 50 attempted to destroy evidence and flee the media, and mentions the possibility of future charges for perjury or criminal contempt.

People (1)

Name Role Context
Juror No. 50 Juror / Subject of Investigation
Subject of legal arguments regarding discovery and standing; accused of trying to distance himself from statements an...

Organizations (3)

Name Type Context
Department of Justice (DOJ)
Indicated by Bates stamp DOJ-OGR.
Southern District of New York (S.D.N.Y.)
Jurisdiction mentioned in case citations.
2d Circuit Court of Appeals
Cited in legal precedent.

Timeline (1 events)

2022-03-11
Filing of Document 642 in Case 1:20-cr-00330-PAE
S.D.N.Y.
Government Attorneys Court

Locations (1)

Location Context
Mentioned in a case citation regarding property forfeiture (United States v. All Right, Title & Int. in Prop...).

Relationships (1)

Juror No. 50 Adversarial/Investigative Government/Prosecution
Government argues against providing discovery to Juror No. 50 and suggests potential criminal charges.

Key Quotes (4)

"sought to distance himself from his original statements, attempted to destroy evidence, and tried to flee from the media."
Source
DOJ-OGR-00009752.jpg
Quote #1
"Any advance disclosure to Juror No. 50 of the questionnaire will undoubtably color Juror No. 50’s testimony and allow him to place himself in the best possible posture."
Source
DOJ-OGR-00009752.jpg
Quote #2
"Although there may come a time when Juror No. 50 is entitled to this discovery—if he is charged with perjury, criminal contempt, or some other crime, for example—the time is not now."
Source
DOJ-OGR-00009752.jpg
Quote #3
"Juror No. 50’s filings should be stricken or, alternatively, remain under seal."
Source
DOJ-OGR-00009752.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (1,733 characters)

Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 60 of 66
sought to distance himself from his original statements, attempted to destroy evidence,
and tried to flee from the media.
Under analogous circumstances courts have refused discovery to individuals or
entities under investigation. See John Doe Agency v. John Doe Corp., 493 U.S. 146,
(1989) (recipient of a grand jury subpoena for certain records relating to a cost allocation
appropriately denied access to records pursuant to a FOIA request).
Any advance disclosure to Juror No. 50 of the questionnaire will undoubtably
color Juror No. 50’s testimony and allow him to place himself in the best possible
posture. Although there may come a time when Juror No. 50 is entitled to this
discovery—if he is charged with perjury, criminal contempt, or some other crime, for
example—the time is not now.
C. Juror No. 50’s filings should be stricken or, alternatively, remain under
seal.
Whether a claimant has standing is “the threshold question in every federal case,
determining the power of the court to entertain the suit.” In re Gucci, 126 F.3d 380, 387–
88 (2d Cir. 1997) (citing Warth v. Seldin, 422 U.S. 490, 498, (1975)). Striking the
pleading of a putative litigant is appropriate where the litigant lacks standing. United
States v. All Right, Title & Int. in Prop., Appurtenances, & Improvements Known as 479
Tamarind Drive, Hallendale, Fla., No. 98 CIV. 2279 DLC, 2011 WL 1045095, at *2
(S.D.N.Y. Mar. 11, 2011). A stricken pleading is a nullity with no legal effect. Davis v.
Bombardier Recreational Prod., Inc., No. 3:11CV236-TSL-MTP, 2012 WL 112202, at
*3 (S.D. Miss. Jan. 12, 2012) (stricken amended complaint deemed a nullity and of
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DOJ-OGR-00009752

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