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This document is page 62 of a legal filing (Document 642) from the Ghislaine Maxwell case (1:20-cr-00330-PAE), dated March 11, 2022. It presents legal arguments citing 'Brown v. Maxwell' and 'Lugosch v. Pyramid Co.' regarding the definition of 'judicial documents' and the presumption of public access. The filing argues specifically against releasing 'Juror No. 50's pleadings,' claiming that doing so would generate prejudicial publicity and infringe upon Ms. Maxwell's right to a fair trial.

This legal document, part of case 1:20-cr-00330-PAE filed on February 24, 2022, presents an argument on behalf of Ms. Maxwell that Juror No. 50 intentionally provided false answers to questions during the jury selection process (voir dire). The document asserts that Ms. Maxwell can meet the burden of proof to show the juror's dishonesty and that the court should infer bias, citing legal precedents to support its claims. The filing suggests that video evidence of the juror being confronted with the false answers supports the claim of intentional deception.

This legal document argues that the government's reliance on the Tanner and Ianniello legal precedents is incorrect in the case of Ms. Maxwell. The author contends that unlike those cases, the alleged misconduct by Juror No. 50 occurred outside the jury room, specifically through false answers during voir dire and subsequent self-publicity. The document asserts that Ms. Maxwell is entitled to an evidentiary hearing and that the juror's own actions in seeking the limelight are the reason the misconduct came to light.

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 legal document is a portion of a motion filed on behalf of Ms. Maxwell, arguing that the court should investigate potential misconduct by two jurors. The motion contends that Rule of Evidence 606(b) does not bar an inquiry into Juror No. 50's alleged bias and false statements, and that a second juror who alerted the New York Times about being a victim of childhood sexual abuse should also be questioned. The argument is that failing to investigate these matters violates Ms. Maxwell's constitutional rights to a fair and impartial jury.

This legal document, part of a court filing, argues that Juror No. 50 should not be granted discovery, specifically a copy of his questionnaire, in advance of a hearing regarding his alleged misconduct. The filing contends that the juror's presence on the jury violated Ms. Maxwell's Sixth Amendment rights to a fair trial, constituting a reversible error that should lead the Court to vacate the verdict.

This document is page 28 of a legal filing (Document 616) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), dated February 24, 2022. It argues that Rule of Evidence 606(b) should not prevent an inquiry into juror misconduct, citing constitutional rights and the precedent of *Pena-Rodriguez v. Colorado*. The text specifically alleges that 'Juror No. 50' showed bias and lied during *voir dire*, and reveals that a 'second juror' contacted the *New York Times* admitting they were a victim of childhood sexual abuse but failed to disclose this on the jury questionnaire (Question 48).

This legal document, filed on February 24, 2022, discusses the jury selection process for Ms. Maxwell's trial, specifically focusing on Juror No. 50. The defense argues that the Court's questioning of this juror, who had a history of abuse but answered 'no' to related questions, was insufficient to determine if he could be fair and impartial. The document suggests the Court failed to probe potential biases that could affect the evaluation of Ms. Maxwell's defense.

This legal document, part of case 1:20-cr-00330-PAE, argues that a juror (Juror No. 50) in Ms. Maxwell's trial failed to disclose his own history as a victim of child abuse during jury selection. The filing asserts that this lack of candor was prejudicial to the defendant, as the defense would have immediately challenged the juror for cause had the truth been known. The document highlights that the Court had denied the defense's requests for more thorough questioning but had assured them it would identify dishonest jurors.

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 page from a legal filing (Case 1:20-cr-00330-PAE) argues that Juror No. 50 failed to disclose childhood sexual abuse during jury selection. The defense contends that had this information been known, Ms. Maxwell would have successfully challenged the juror for cause due to inherent bias. The text notes that the juror later spoke to the media about his trauma but is now attempting to walk back those comments after being warned by the government of potential legal consequences.

This legal document, part of case 1:20-cr-00330-PAE, argues for a new trial for Ms. Maxwell. The basis for the argument is that Juror No. 50 provided a false answer on a jury questionnaire regarding their personal experience with sexual assault, which was a core issue in the case. This alleged dishonesty is claimed to have undermined the jury selection process (voir dire) and deprived Ms. Maxwell of her constitutional right to a fair trial by an impartial jury.

This document is the table of contents for a legal motion filed on February 24, 2022, on behalf of Ms. Maxwell. The motion argues for a new trial, primarily on the grounds that Juror No. 50 provided deliberately false answers during the jury selection process (voir dire). The document outlines the legal arguments, challenges the government's position, and discusses the procedures for a potential hearing on the matter.

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 document is the table of contents for a legal filing in Case 1:20-cr-00330-PAE, filed on February 24, 2022. The filing argues that the defendant, Ms. Maxwell, was deprived of a fair trial due to juror misconduct, focusing on "Juror No. 50," who allegedly was untruthful during jury selection and later gave interviews to media outlets like The Independent, Daily Mail, and Reuters. The document also notes that a second juror disclosed during deliberations that they had been a victim of sexual assault.

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 document is the table of contents for a legal filing in Case 1:20-cr-00330-PAE, filed on February 24, 2022. The main argument is that Ms. Maxwell is entitled to a new trial because Juror No. 50 allegedly provided untruthful answers during the jury selection process (voir dire). The document also addresses arguments against Juror No. 50's right to intervene or make discovery requests, citing an ongoing investigation into the juror.

Page 16 of a legal filing (Document 644) in the case against Ghislaine Maxwell, filed March 11, 2022. The defense argues that Ms. Maxwell is entitled to a new trial or hearing because Juror No. 50 failed to truthfully answer voir dire questions 25 and 48, preventing the defense from challenging the juror for cause. The text disputes the government's position on the burden of proof, citing precedents such as McDonough, Langford, and United States v. Stewart.

This legal document argues that Ms. Maxwell is entitled to a new trial. The basis for the argument is that a juror, identified as Juror No. 50, provided false answers during the jury selection process (voir dire) by denying he had ever been a victim of a crime or sexual abuse. The document asserts that the juror later admitted to media outlets that he was a victim of childhood sexual abuse, and that this dishonesty was material to his ability to serve as an impartial juror, thus satisfying the legal test for a new trial.

This legal document is a page from a motion filed on behalf of Ms. Maxwell, arguing that she is entitled to a new trial due to false answers given by Juror No. 50 during jury selection. The central argument is that Maxwell does not need to prove the juror's falsehoods were deliberate, citing several legal precedents to support the claim that even honest mistakes can warrant a new trial to ensure the constitutional right to a fair and impartial jury. The motion criticizes the government's position as a weak attempt to achieve "finality" at the expense of justice.

This legal document, filed on March 11, 2022, is part of a motion on behalf of Ms. Maxwell arguing for a new trial. The central claim is that she does not need to prove that Juror No. 50's false answers during jury selection were deliberately made. The document cites multiple legal precedents to support the argument that even an honest but mistaken answer from a juror can be grounds for a new trial, especially when it raises questions of juror bias.

This legal document argues that the government's reliance on the Tanner and Ianniello precedents is misplaced in the case of Ms. Maxwell. The author contends that unlike those cases, which dealt with conduct during deliberations, this case involves a juror (Juror No. 50) who gave false answers during voir dire—conduct outside the jury room—and therefore an evidentiary hearing is warranted. The document further notes that the juror has actively sought public attention, which is how his false answers became known.

This legal document is a filing on behalf of Ms. Maxwell arguing against the government's proposal for a limited evidentiary hearing concerning Juror No. 50. The defense contends that the juror's alleged false answers necessitate a reversal, citing Supreme Court precedent, and that Ms. Maxwell has a constitutional right to a full adversarial hearing, not the narrow one proposed by the government. The filing draws parallels to the United States v. Daugerdas case to support its claim for a new trial.

This legal document, filed on February 24, 2022, is part of a case involving Ms. Maxwell. The filing argues that the questioning of 'Juror No. 50' should be broad and encompass any topic related to actual bias, citing legal precedents like Greer and United States v. James. It asserts that due to the juror's alleged pattern of giving false answers, Ms. Maxwell is not required to accept the juror's denial of acting deliberately and should be allowed to investigate the totality of the circumstances.

This is a page from a legal filing in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), dated February 24, 2022. The document argues that Juror No. 50 falsely answered questions during jury selection (voir dire) and requests subpoenas for the juror's emails with alleged victims, witnesses, or other jurors.

This legal document, filed on March 11, 2022, presents an argument on behalf of Ms. Maxwell that Juror No. 50 intentionally provided false answers to questions during the jury selection process (voir dire). The document asserts that Ms. Maxwell has met the burden of proof for this claim, citing legal precedents and suggesting that video evidence of the juror being confronted supports the allegation of intentional falsehood. The ultimate goal is to argue for the juror's implied or actual bias.

This document is a page from a court filing (Case 1:20-cr-00330-PAE) dated January 19, 2022, arguing that Ms. Maxwell's guilty verdict should be vacated. The text alleges that Juror No. 50 and at least one other juror were dishonest during the *voir dire* process, violating the defendant's Constitutional right to a fair and impartial jury. The defense requests a new trial or, alternatively, an evidentiary hearing to examine all twelve jurors.

This legal document, filed on March 11, 2022, argues for a new trial for a defendant, Ms. Maxwell. The basis for the request is the allegation that Juror No. 50 provided a false answer on a jury selection questionnaire regarding personal experience with sexual assault, which was a core issue in the case. This alleged dishonesty is claimed to have resulted in an unfair and impartial jury, thereby depriving Ms. Maxwell of her constitutional right to a fair trial.

This document is the table of contents for a legal filing in Case 1:20-cr-00330-PAE, filed on March 11, 2022. The filing argues that the defendant, Ms. Maxwell, was deprived of a fair trial due to juror misconduct. The primary focus is on "Juror No. 50," who allegedly was untruthful during voir dire and subsequently gave media interviews; it also mentions a second juror who disclosed during deliberations that they were a victim of sexual assault.

This document is page 8 of a legal filing (Document 644) in the case United States v. Ghislaine Maxwell, filed on March 11, 2022. The text argues that 'Juror No. 50' committed misconduct by failing to disclose a history of child sexual abuse, which mirrors the charges against Maxwell. The defense contends that the government's comparison to other jurors who experienced minor harassment is misleading and urges the Court to investigate the claim to ensure Maxwell's right to an impartial jury.

This legal document, filed on February 24, 2022, is part of a motion on behalf of Ms. Maxwell arguing for a new trial or other relief due to juror misconduct. The filing contends that Juror No. 50 was not impartial, citing his 'pattern and practice of telling falsehoods' under oath during jury selection (voir dire). The document refutes the government's counterarguments and uses legal precedents like McDonough and Greer to support the claim that the juror's deliberate lies are evidence of bias and that the court would have struck him for cause had the truth been known.

This legal document is a filing on behalf of Ms. Maxwell arguing that the court should strike all filings made by 'Juror No. 50.' The argument posits that the juror, as a non-party, lacks standing and that the filings are an improper attempt at discovery, not 'judicial documents' entitled to public access. Alternatively, it requests that the juror's filings remain sealed pending the outcome of Ms. Maxwell's motion for a new trial, which is based on the same juror's alleged dishonesty during jury selection.

This legal document, filed on March 11, 2022, argues that Juror No. 50 was not impartial and failed to honestly disclose his past as a victim of sexual abuse during jury selection. The filing contends that this omission prevented the Court and defense from properly assessing his ability to be fair, particularly regarding the testimony of Dr. Loftus and the defense of Ms. Maxwell. The document suggests that had the juror been truthful, further inquiry would have been made, and his claim of impartiality is not credible.

This legal document, part of case 1:20-cr-00330-PAE filed on February 24, 2022, presents an argument on behalf of Ms. Maxwell regarding juror misconduct. It contends that the government's view—that Maxwell must carry a heavier burden of proof because Juror No. 50 was untruthful during jury selection—is unfair and incorrect. The argument cites legal precedents, including McDonough and United States v. Stewart, to establish the proper standard for challenging a juror based on false voir dire responses.

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.