| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Juror 50
|
Juror candidate |
5
|
1 | |
|
person
Cynthia Hopkins
|
Employee |
1
|
1 |
This legal document details the testimony of Juror 50 regarding an inaccurate answer he provided on a jury questionnaire. Juror 50 claims the error was an "inadvertent mistake" caused by skimming the question too quickly and being distracted by the environment in the courthouse. The document contrasts the juror's explanation with the defendant's legal argument that the juror's actions satisfy the first prong of the McDonough test for juror dishonesty.
This document is page 10 of a legal filing from March 2022 in the US v. Maxwell case. The defense argues that a Jury Note regarding Count Four indicates the jury was considering convicting Maxwell based on intent for sexual activity occurring in New Mexico, which the defense claims raises a 'constructive amendment' issue. The text disputes the government's interpretation of the note, accusing the government of inserting a comma to alter the meaning and downplay the jury's focus on New Mexico.
This document is a court transcript where an attorney, Ms. Davis, argues against a motion for a new trial. She references a letter from Catherine Conrad about jury deliberations concerning David Parse, noting the jury struggled with the legal definitions of 'wilfully' and 'knowingly' but ultimately made a deliberate and informed decision, as evidenced by their verdict on conspiracy and tax evasion counts. The discussion highlights the legal nuances that influenced the jury's split verdict.
This document is the signature page of a legal affidavit signed by David Parse on August 3, 2012. The text discusses a conclusion reached by 'Brune lawyers' regarding an individual named Conrad, determining that Conrad was not a suspended attorney and that the Court did not need to be informed. The document bears a DOJ Bates stamp and appears to be an exhibit in a later case.
This document is a page from a legal analysis, likely a judicial opinion, dated April 6, 2012, concerning the conduct of defense lawyers in case 1:09-cr-00581-WHP. The author examines statements made by the lawyers in a July 8, 2011 memorandum regarding their investigation into a juror named Conrad, concluding that while the statements could lead to a false inference, they do not constitute a knowing misrepresentation or unethical behavior. The document also recounts a July 15 telephone conference where the Court questioned the defense team, represented by Trzaskoma, about their awareness of issues with the juror.
This legal document, filed on April 6, 2012, presents an opinion on the ethical obligations of Brune & Richard lawyers concerning disclosures related to a new trial motion involving juror Conrad. It concludes that the lawyers did not violate their ethical obligations in their research, motions, or communications with the Court. The opinion is based on a review of various legal documents and transcripts, and references the New York Rules of Professional Conduct.
This document is a page from a court transcript of the direct examination of a witness named Brune. The witness corrects a previous statement about a timeline, clarifying that Ms. Trzaskoma handled a telephone conference with the Court on May 15th, and that the witness first learned about the relevant voir dire on July 18th. The witness also describes another individual, Ms. Edelstein, as being a "very thorough person."
This document is an excerpt from a legal proceeding, likely a deposition or court transcript, featuring a direct examination by 'Brune' of a speaker identified as 'C2GFDAU1'. The discussion revolves around a past court event where a judge had to restart jury deliberations due to a juror's illness, which coincided with Mr. Rosenbaum having to leave. The witness explains why they did not raise a particular issue with the Court at an earlier time.
This document is a court transcript from a direct examination of a witness named Brune. Brune testifies that they had no concerns about the behavior of a particular juror and recounts the circumstances surrounding a note sent by Juror No. 1 on May 10th. The witness recalls that Judge Pauley disclosed the note to the court only after summations were complete, believing it would have been unfair to do so in the middle of them.
This document is a court transcript of the direct examination of a witness named Brune. Brune confirms being present for every day of a trial, having a direct view of the jury box, and observing a specific juror, Ms. Conrad, as being attentive and taking a lot of notes.
This document is a table of contents for exhibits attached to a 'Trzaskoma Declaration' in a legal case. The exhibits primarily concern an individual named Catherine Conrad (also referred to as Catherine M. Conrad and Catherine Morgan Conrad) and include various legal and personal documents. These documents range from a 1998 criminal court disposition to a 2007 marriage certificate and a 2011 letter, suggesting a compilation of background information for a legal proceeding.
This document is a Certificate of Service filed on March 11, 2022, for the case 1:20-cr-00330-PAE. Signed by Nicole Simmons, it certifies that on February 9, 2022, "Ghislaine Maxwell’s Reply in Support of Her Motion for a New Trial" was electronically filed with the court and served to the government's counsel at the U.S. Attorney's Office in New York.
This legal filing argues that the government is mischaracterizing the record concerning Juror No. 50's responses during jury selection. The document contends that, unlike other jurors, Juror No. 50's specific claim of childhood sexual abuse was directly relevant to the case, and had he disclosed his belief that memory works 'like a video-tape' during the trial, the Court would have questioned his ability to fairly evaluate expert testimony on the topic.
This legal document presents an argument on behalf of Ms. Maxwell, asserting that Juror No. 50 engaged in misconduct by providing false answers under oath during jury selection (voir dire). The filing refutes the government's counterarguments, claiming the juror's dishonesty about being a victim of sexual abuse and his use of Twitter demonstrates implied bias and a deliberate pattern of falsehoods that should have resulted in his exclusion from the jury.
This legal document, part of a court filing, argues that a new trial is necessary due to the implied and inferable bias of Juror No. 50. The author contends that if the juror had answered voir dire questions truthfully, it would have provided a valid basis for a challenge for cause. The document refutes the government's legal arguments by citing precedents like United States v. Daugerdas and United States v. Torres, and suggests a hearing is needed to evaluate the juror's actual partiality.
This legal document is a filing on behalf of Ms. Maxwell arguing against the government's proposal for a limited evidentiary hearing regarding Juror No. 50. The defense contends that the juror's presence, due to alleged false answers and bias, requires a reversal, citing Supreme Court precedent in 'United States v. Martinez-Salazar'. The filing asserts that the government's proposed narrow hearing would violate Ms. Maxwell's constitutional rights and argues that precedent from 'United States v. Daugerdas' supports her entitlement to a new trial.
This legal document argues against the defendant's position that Juror 50's motion to intervene should be sealed. The author asserts that the motion is a judicial document that should be publicly docketed, citing the case Lugosch v. Pyramid Co. of Onondaga and refuting the defendant's claims that it is merely a discovery request or that public filing would interfere with testimony. A footnote defends the Government's prior action of publicly filing a letter about Juror 50's public statements, stating it was appropriate and that an attempt was made to confer with defense counsel beforehand.
This legal document is a court filing that refutes the defendant's argument that the court failed to properly question Juror 50 about potential biases. The filing asserts that Juror 50 repeatedly confirmed his ability to be impartial and decide the case based on the evidence, and that the court's voir dire process was correct in not delving into specific defense theories, citing legal precedent about the purpose of jury selection.
This legal document argues that a hearing to question Juror 50 should be strictly limited in scope and conducted by the Court itself. The author contends the inquiry should only focus on whether the juror intentionally lied in response to specific voir dire questions and was actually biased, citing legal precedent and Federal Rule of Evidence 606(b) to prevent improper questioning about jury deliberations. This approach is recommended to avoid harassment of the juror regarding sensitive topics like sexual abuse and to prevent the defendant from introducing inadmissible subjects.
This legal document is a filing by the Government arguing that the Court should personally conduct a narrowly tailored questioning of Juror 50 to investigate potential bias. The Government contends this approach is necessary to prevent juror harassment and is within the Court's discretion, citing several legal precedents from the Second Circuit and district courts to support its position. The filing opposes the defendant's request for 'pre-hearing discovery' and argues against calling other jurors as witnesses.
This legal document, a page from a court filing, discusses the issue of juror bias in sexual abuse cases. The author argues against a mandatory presumption of bias for jurors who are survivors of sexual abuse, citing legal precedents like State v. Ashfar and Torres. The document asserts that the court correctly conducted targeted inquiries into jurors' ability to be impartial, rather than automatically striking them, noting that a contrary rule would disqualify a large portion of the jury pool.
This legal document is a filing by the Government in response to a defendant's motion. The Government argues that there is no evidence Juror 50 deliberately lied about his social media use, but acknowledges an inconsistency between the juror's public statements about being a victim of sexual abuse and his answer to a questionnaire. The Government agrees that a limited evidentiary hearing is warranted to determine if the juror answered falsely and whether it was intentional.
This legal document argues against a defendant's claim that Juror 50 intentionally lied on a juror questionnaire about being a victim of sexual abuse in order to serve on the jury. The filing contends that Juror 50's other disclosures, such as his knowledge of the defendant's connection to Epstein, are inconsistent with an intent to deceive. It cites legal precedents to support the idea that juror questionnaires should be viewed in context and suggests the matter of credibility should be resolved in a formal court hearing.
This legal document, dated January 19, 2022, argues that Ms. Maxwell was denied her constitutional right to a fair trial because at least one juror, identified as Juror No. 50, was dishonest during the jury selection (voir dire) process. The filing requests that the Court either vacate the jury's verdict and order a new trial, or alternatively, hold an evidentiary hearing to question all twelve jurors.
This legal document, filed on March 11, 2022, is a request by Ms. Maxwell to the Court for pre-hearing discovery. She asks the court to authorize subpoenas for the communications of Juror No. 50, who is alleged to have answered a question falsely during voir dire. The request seeks emails and other written communications between Juror No. 50 and any alleged victims, witnesses, or other jurors in the case to investigate potential juror misconduct.
| Date | Type | From | To | Amount | Description | Actions |
|---|---|---|---|---|---|---|
| 2009-09-17 | Received | Burman, Critton, ... | Court | $138.80 | Invoice for cancelled deposition services (Appe... | View |
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