Event Details

This is page 4 of a legal filing (Document 649) from the Law Offices of Bobbi C. Sternheim, filed on March 15, 2022, in the case of United States v. Maxwell. The text argues that 'Juror 50' demonstrated bias by lying on a questionnaire about his own history of sexual abuse, which the defense argues closely paralleled the abuse described by victims at the trial. The filing highlights that the juror was abused by a familiar person (his stepbrother), mirroring the allegations against Epstein and Maxwell, and argues he would have been struck for cause had he been honest.

This document is a page from a court transcript (page 286) filed on February 24, 2022. It features the direct examination testimony of Ms. Brune (likely a defense attorney), who is being questioned about her failure to bring Google search results regarding a juror to the Court's attention during or after voir dire. Brune defends her actions by stating she believed the information she found referred to a different person than the juror, based on the juror's sworn statements claiming to be a 'stay at home wife' rather than an attorney. Brune also affirms her obligation to the Court remains the same as when she was an Assistant US Attorney (AUSA).

This document is page 23 of a legal filing (Document 643) in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on March 11, 2022. It contains the Government's legal argument arguing that the Defendant's claims regarding juror bias are unpersuasive. The text defines 'actual bias' versus 'implied' or 'inferable' bias, citing precedents such as United States v. Torres and Smith v. Phillips to argue that actual bias is the only relevant inquiry in a post-trial context.

This document is a page from a court transcript (filed August 24, 2022) featuring the direct testimony of a witness named Brune. The testimony concerns the due diligence performed during jury selection (voir dire), specifically admitting that the witness did not launch a full-scale private investigation into every juror and confirming that the investigative entity 'Nardello' did not search for juror Catherine M. Conrad of Bronxville. The witness also discusses the timing of when the government disclosed a letter sent by the juror.

This document is page 26 of a legal filing from March 11, 2022, in the case of United States v. Ghislaine Maxwell. The text argues that the Court must conduct a broad inquiry into Juror No. 50's potential bias and intent, asserting that the juror has a history of giving false answers. It contrasts Juror No. 50 with Jurors 189 and 239, who properly disclosed details of past sexual abuse in written questionnaires, though the specific details of that abuse are redacted in this document.

This document is page 6 of a court order (Document 620) filed on February 25, 2022, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The text discusses the legal standards required to hold a 'McDonough hearing' regarding juror nondisclosure, citing Second Circuit precedents that set a high bar for post-verdict inquiries to prevent juror harassment and 'fishing expeditions.' The court notes that the Defendant (Maxwell) argues against this standard but fails to provide an alternative.

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) featuring the direct examination of a witness by Mr. Schoeman. The testimony details a conversation between the witness and Ms. Trzaskoma while walking across Foley Square, concerning Juror No. 1 (Ms. Conrad). They discussed a disbarred lawyer with the same name as the juror but concluded it was a different person because the juror's educational background did not include law school.

This document is page 57 of a legal filing (Document 642) from the US v. Ghislaine Maxwell case (1:20-cr-00330-PAE), filed on March 11, 2022. In the text, Maxwell's defense requests a specific protocol for a hearing to question Juror No. 50 and potentially a second juror regarding allegations that they gave false answers during voir dire. The defense argues that this inquiry is necessary to prove the jury was not fair and impartial under the Sixth Amendment and asserts that Federal Rule of Evidence 606(b) does not prohibit this inquiry as they are not impeaching the verdict based on deliberations.

This document is a page from a court transcript (Exhibit A-5716) filed on Feb 24, 2022, in the case US v. Ghislaine Maxwell. The witness, identified as Brune, is being questioned about the legal team's use of technology and personnel during the trial, specifically mentioning Donna Kane from Decision Quest regarding graphics. The testimony confirms that team members Theresa Trzaskoma and Lori Edelstein had laptops and internet/email access in the courtroom during voir dire and jury deliberations.

This document is page 297 of a court transcript (Case 1:20-cr-00330-PAE) featuring the direct examination of a witness named Ms. Brune by attorney Mr. Davis. The questioning focuses on a previous statement made by Ms. Trzaskoma regarding a 'suspension opinion' and a 'Westlaw report' that came to light before voir dire. Mr. Davis is pressing the witness to confirm that a Westlaw report was attached to a letter submitted to the court.

This document is a transcript page from a court proceeding (likely related to United States v. Ghislaine Maxwell, given the case number) filed on February 24, 2022. The witness, identified as 'Brune' (likely defense attorney Susan Brune), is testifying about the defense team's jury research process, specifically regarding juror Catherine M. Conrad. Brune admits that the investigative firm Nardello did not search for Conrad and discusses the timing of when the team focused on the juror's middle initial relative to a letter disclosed by the government.

This document is page 42 of a legal filing (Document 613) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on February 24, 2022. It argues that 'Juror No. 50' demonstrated implied bias through post-trial conduct, specifically communicating with victim Annie Farmer (spelled 'Famer' in text) and making public statements that the verdict was 'for all the victims.' The text also alleges the juror lied during voir dire to secure a spot on the jury, citing case law (Daugerdas) regarding juror dishonesty.

This document is page 50 (PDF page 57) of a legal filing dated February 24, 2022, in the case of United States v. Ghislaine Maxwell. The defense requests a hearing to question Juror No. 50 regarding potential bias, alleging that at least two jurors gave false answers during voir dire which violated Maxwell's Sixth Amendment rights. The filing argues that Federal Rule of Evidence 606(b) does not prohibit this inquiry as it pertains to juror qualifications rather than the content of deliberations.

This document is a page from a transcript of testimony given by an individual named Edelstein. The testimony concerns the drafting of a legal brief and whether the legal team knowingly omitted information regarding a suspended lawyer named Catherine Conrad prior to voir dire (jury selection). The witness explains their focus was on establishing identity rather than waiving rights regarding juror misconduct.

This document is a page from a legal filing by Ghislaine Maxwell's defense team, arguing that Juror No. 50 should not be given access to a sealed questionnaire prior to a potential hearing, as it might allow him to fabricate excuses. The defense concludes that the prosecution is applying a double standard regarding juror misconduct and asserts that Maxwell's Sixth Amendment rights were violated by the juror's presence, requesting the court vacate the conviction (implied by cut-off text).

This document is a Table of Contents page (page ii) from a legal appeal filed on February 28, 2023. It outlines arguments regarding the Statute of Limitations (Point II) and allegations that Juror No. 50 made false statements during voir dire, denying Ms. Maxwell a fair trial (Point III). The document specifically references the Mann Act, Section 3283, and the McDonough Test regarding juror bias.

This document is page 29 of a legal filing (Case 1:20-cr-00330-PAE) filed on March 11, 2022, arguing for a new trial or evidentiary hearing based on juror misconduct. The defense argues that a second juror (besides Juror No. 50) failed to disclose being a victim of childhood sexual abuse during voir dire, citing a New York Times article and Juror No. 50's statements as evidence. The document also argues that Ms. Maxwell is entitled to discovery regarding communications outside of deliberations, specifically referencing social media material.

This document is page 13 of a court order filed on April 1, 2022, in the case against Ghislaine Maxwell. The text analyzes a motion regarding juror misconduct, specifically discussing the 'McDonough' test. The Court concludes that the juror's false answers during voir dire were not deliberate and that the second prong of the legal test was not satisfied. It also defines legal standards for actual, implied, and inferable bias.

This document is page 73 of a legal appellate brief filed on February 28, 2023, related to the Ghislaine Maxwell case (Case 22-1426). The text argues that the trial court erred regarding 'Juror 50,' claiming the juror had a bias regarding sexual abuse memories that should have disqualified them. It also argues 'Point IV,' stating the court constructively amended the indictment by allowing the jury to convict Maxwell on Count Four based on activity in New Mexico (testified to by 'Jane') that was not a violation of New York law.

This document is page 4 of a legal filing from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on February 25, 2022. It discusses a motion for a new trial based on 'Juror 50' allegedly failing to disclose information (specifically regarding childhood sexual abuse) during voir dire. The text outlines the legal standards for such a motion, citing Federal Rule of Criminal Procedure 33 and the Supreme Court case *McDonough Power Equipment, Inc. v. Greenwood*.

This document is a page from a court transcript filed on March 11, 2022, from the case USA v. Maxwell (Case 1:20-cr-00330). It records a discussion between the Judge and defense attorneys (Mr. Everdell and Ms. Sternheim) regarding a juror who had posted on social media and was a victim of sexual abuse himself. The defense argues that the juror's history and desire to be on an 'interesting' jury involving sexual abuse victims impact his ability to be impartial, and they discuss whether he followed court instructions during voir dire.

This page is from a legal filing (Document 615) in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330), filed on February 24, 2022. The text argues against the defendant's motion claiming juror bias, specifically discussing the legal standards for 'actual bias' versus 'implied' or 'inferable' bias in a post-trial context. The Government argues that actual bias is the only relevant inquiry and cites various legal precedents (Torres, Greer, Smith v. Phillips) to support the position that the defendant's arguments are unpersuasive.

This document is page 15 of a legal filing dated March 15, 2022, from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). The text argues against the defendant's motion for a new trial, asserting that Juror 50 was fair and impartial despite disclosing past sexual abuse. The filing contends the defendant failed to meet the 'McDonough test' requirements to prove juror bias.

This document is page 13 of a court order (Case 1:20-cr-00330-AJN, United States v. Ghislaine Maxwell) filed on April 1, 2022. The Court is analyzing a motion regarding juror misconduct, specifically applying the *McDonough* test to determine if a juror's false answers during *voir dire* necessitate a new trial. The Court ultimately finds that the juror's false answers were not deliberate and proceeds to analyze the second prong of the test regarding bias (actual, implied, or inferable).

This document is a court ruling from April 1, 2022, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The Court rejects the Defendant's argument that 'Juror 50' was biased for failing to follow instructions during the jury questionnaire phase. The Court accepts Juror 50's testimony that while he was distracted (thinking about his ex) during the questionnaire, he was fully attentive and compliant during voir dire and the actual trial.

This document is a page from a legal filing (Case 1:20-cr-00330, likely United States v. Ghislaine Maxwell) filed on March 15, 2022. It argues against the defendant's motion for a new trial, specifically addressing allegations regarding 'Juror 50' and citing the 'McDonough' test for juror misconduct. The text asserts the defendant failed to prove the juror committed a deliberate falsehood during voir dire.

This is a court transcript page filed on February 24, 2022, from the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330). A witness named Edelstein is being questioned about whether their legal team had the resources to investigate Juror No. 1, Catherine Conrad, specifically regarding a prior personal injury lawsuit she failed to fully disclose during voir dire. Edelstein admits they had the resources to call investigators (Nardello) but did not do so initially because they didn't believe the Catherine Conrad in the Westlaw report was the same person as the juror.

This document is a page from a court transcript (Case 1:20-cr-00330-AJN) filed on February 24, 2022. It features testimony from a witness named Edelstein regarding a discussion with Ms. Trzaskoma about Juror No. 1. They debated whether the juror was a suspended lawyer named Catherine Conrad but concluded at the time that it was 'inconceivable' based on voir dire responses, specifically regarding education.

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.

This document is the Table of Contents for a court filing (Document 615) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on February 24, 2022. The filing appears to be the Government's response arguing against the Defendant's motion for a new trial, specifically addressing issues surrounding 'Juror 50' regarding their questionnaire, voir dire, and post-verdict public statements. The outline proposes a limited hearing to question Juror 50 while arguing that the defense has not met the legal standards (McDonough test) to warrant a new trial.

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.

This page from a legal filing (Case 22-1426) discusses a Rule 33 motion for a new trial based on 'Juror 50's' alleged erroneous responses during jury selection (voir dire). The text argues that the District Court correctly applied the 'McDonough' standard, finding the juror's errors were not deliberate and that accurate answers would not have led to a dismissal for cause. It also notes that Ghislaine Maxwell did not challenge other jurors who had disclosed histories of sexual abuse.

This document is a page from a court order (Case 1:20-cr-00330, US v. Maxwell) filed on April 1, 2022. The Court rejects the Defendant's argument that 'Juror 50' was biased based on post-trial statements claiming the verdict was for the victims. The text discusses implied bias related to the juror's personal history of sexual abuse and references legal precedents regarding post-trial juror statements.

This document is page 3 (Table of Contents) of a legal filing from Case 1:20-cr-00330-PAE, dated March 11, 2022. It outlines arguments claiming Ghislaine Maxwell is entitled to a new trial because 'Juror No. 50' allegedly answered voir dire questions (specifically 25 and 48) falsely. The document also argues against Juror No. 50's right to intervene or receive discovery, noting the juror is currently under investigation.

This document is page 29 of a legal brief (Case 22-1426) filed on July 27, 2023. It argues that 'Juror 50' should have been excluded from the Maxwell case due to implied bias, specifically citing the 'average person test' and the juror's failure to disclose victimization during voir dire. The text cites multiple legal precedents (Smith v. Phillips, U.S. v. Burr) to support the claim that nondisclosure of sexual abuse victimization deprives the court of vital information.

This document is page 18 of a legal filing (Case 22-1426) dated September 17, 2024. It discusses a Rule 33 motion regarding Juror 50's erroneous responses during voir dire in the Ghislaine Maxwell trial. The text argues that under the 'McDonough' standard, a new trial is not warranted because the District Court found the juror's errors were not deliberate and would not have resulted in a strike for cause.

This document is a page from a legal brief filed by the prosecution on February 25, 2022, in the case against Ghislaine Maxwell. It argues against the Defendant's motion for a new trial based on alleged juror misconduct (specifically regarding 'Juror 50' and a 'second juror' lying during voir dire). The text cites Federal Rule of Evidence 606 and the Supreme Court case Warger v. Shauers to argue that juror testimony regarding internal deliberations or personal experiences is inadmissible and does not constitute 'extraneous prejudicial information.'