This is page 15 of a legal filing (Document 643) from the Ghislaine Maxwell case (1:20-cr-00330-PAE), filed on March 11, 2022. The Government argues that the defendant has failed to meet the 'McDonough test' requirements to secure a new trial based on juror misconduct, specifically stating that the defendant must prove the juror committed a 'deliberate falsehood' rather than an honest mistake. Despite this, the Government notes that it consents to a 'limited hearing' on the matter.
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