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This is page 36 of a legal filing (Document 615) in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on February 24, 2022. The text is a government argument refuting the defense's claim that 'Juror 50' needs to be probed further regarding their ability to assess witness credibility in sexual assault cases. The government argues that Juror 50 already affirmed this ability in their questionnaire (Question 47) and that any further inquiry regarding the juror's personal history of abuse should be limited and conducted privately (sidebar or in camera).

This document is page 5 of a court filing (Case 1:20-cr-00330-PAE) dated February 25, 2022. The Court denies the Defendant's (Maxwell) motion for an immediate new trial based on the current record but rules that an evidentiary hearing must be held to investigate Juror 50's alleged nondisclosure of sexual abuse history during jury selection. The text cites the 'McDonough standard' and legal precedents requiring hearings when juror impartiality is in doubt.

This document is Page 19 of a court ruling filed on February 25, 2022, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The Court denies the Defendant's request for pre-hearing discovery, labeling it a 'fishing expedition,' and rules that Juror 50 will be provided a copy of his completed jury questionnaire. The Court also orders that the questionnaire be docketed (unsealed), citing the presumption of public access to judicial documents.

This document is page 9 of a court filing (Document 620) from the United States v. Ghislaine Maxwell case, dated February 25, 2022. The text discusses a post-trial motion regarding 'Juror 50,' specifically addressing whether the juror lied during voir dire about social media usage. The Court ruled that a hearing is warranted regarding specific questionnaire answers but denied the Defendant's request to probe the juror's social media history, citing that the juror's minimal Twitter usage and explanation for deleting apps were consistent with their testimony.

This document is page 20 of a Court Order filed on February 25, 2022, in the case of United States v. Ghislaine Maxwell. The Judge orders that Juror 50's completed questionnaire be unsealed and docketed, citing that public interest outweighs privacy concerns following the juror's public comments. Additionally, the Court schedules a hearing for March 8, 2022, requiring Juror 50 to testify under oath regarding their answers to specific questions on the juror questionnaire.

This legal document, part of case 1:20-cr-00330-PAE, argues against a defendant's motion for a new trial based on alleged juror bias. It focuses on Juror 50, who had a history of sexual abuse, and contends that despite this, the juror consistently affirmed his impartiality during voir dire on November 16, 2021, and a subsequent hearing on March 8, 2022. The filing asserts that Juror 50's testimony demonstrates he was not biased and was capable of rendering a verdict based solely on the evidence and the court's instructions.

This court order page denies the Defendant's (Maxwell) request to investigate Juror 50's social media and to examine other jurors regarding a 'second juror' allegedly abused as a minor. The court rules that Juror 50's Instagram posts were personal and do not warrant a 'fishing expedition,' and that the theory regarding a second juror is unfounded speculation based on a New York Times article. Footnote 5 details a timeline of communications between the court and jurors regarding media harassment, noting that these communications will be shared with the parties under seal with redactions to protect juror privacy.

This document is a page from a Government filing in the case against Ghislaine Maxwell (Case 1:20-cr-00330), dated March 11, 2022. It discusses a dispute regarding 'Juror 50', who has requested access to his own voir dire transcript and juror questionnaire; the defense opposes this, arguing it would prejudice the investigation into the juror's conduct, while the government supports the juror's right to access a document he authored. The text also references a separate motion by The New York Times to unseal juror questionnaires.

This document is page 36 of a court order filed on April 1, 2022, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330). The text discusses the Court's rejection of the Defendant's arguments regarding 'Juror 50,' specifically concerning the juror's history of sexual abuse and 'healing process.' The Court cites Federal Rule of Evidence 606(b) to prevent inquiry into the juror's mental processes during deliberations and concludes that the juror's past trauma did not interfere with his ability to be fair and impartial.

This document is an excerpt from a court order (Case 1:20-cr-00330-AJN, United States v. Ghislaine Maxwell) detailing post-trial motions regarding 'Juror 50'. It discusses the juror's media interviews where he admitted to being a sexual abuse victim despite checking 'no' on his questionnaire, prompting the Defendant to file for a new trial on January 19, 2022. The document also details a phone call on January 5, 2022, where Juror 50 contacted the Jury Department seeking guidance and access to his questionnaire, which was denied.

This document is page 35 of a legal filing (Document 615) from the Ghislaine Maxwell trial (Case 1:20-cr-00330), filed on February 24, 2022. It is a Government argument requesting that the Court limit the scope of an upcoming hearing regarding potential misconduct by 'Juror 50' regarding undisclosed history of sexual abuse. The Government argues the Court should conduct the questioning to protect the juror from harassment and that inquiries must be strictly limited to whether the juror lied on Question 48 or Question 25 of the jury questionnaire.

This document is page 37 of a legal filing (Doc 615) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on February 24, 2022. The text argues against the defendant's claim that the Court should have further probed 'Juror 50' regarding his ability to set aside past traumatic experiences and fairly evaluate the testimony of defense expert Dr. Loftus. The filing cites voir dire transcripts from November 16, 2021, where Juror 50 affirmed his ability to be impartial, and references case law (*United States v. Pirk*, *United States v. Barnes*) regarding the limited purpose of voir dire.

This legal document is a court filing that addresses and rejects the Defendant's arguments for juror bias. The Defendant claims that Juror 50 was biased due to his personal history of sexual abuse, which she argues resonated with the victims' testimony and improperly shaped his views. The Court refutes these claims, stating that the juror's post-trial interviews do not prove pre-trial bias and that it is a foundational principle for jurors to rely on their life experiences to evaluate evidence.

This legal document is a filing that refutes a defendant's claims that a juror, Juror 50, lied during the jury selection process (voir dire). The filing argues there is insufficient evidence to prove the juror deliberately lied about not being a victim of a crime or about his social media usage. It specifically addresses the juror's failure to mention an inactive Twitter account and the claim he deleted his Facebook and Instagram accounts, suggesting these were not material or deliberate falsehoods.

This document is page 18 of a legal filing (Document 615) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on February 24, 2022. It argues that 'Juror 50' made an honest mistake rather than a deliberate falsehood when failing to disclose their history of sexual abuse on the jury questionnaire (specifically Question 48). The text cites transcripts where the juror claims they 'flew through' the form and genuinely did not remember the specific question asking about personal victimization.

This document is page 48 of a court filing from the Ghislaine Maxwell case (1:20-cr-00330-PAE), dated February 24, 2022. The text argues against the defendant's request to seal Juror 50's motion to intervene, asserting it is a judicial document that should be public. It also defends the Government's previous decision to publicly file a letter regarding Juror 50's public statements, noting that defense counsel failed to respond to attempts to confer prior to that filing.

This legal document is a court ruling from case 1:20-cr-00330-PAE, filed on April 1, 2022. The Court rejects the Defendant's (Maxwell's) post-hearing argument that Juror 50 was biased because he failed to follow instructions on a questionnaire. The Court found that while the juror admitted to being distracted during the questionnaire, he was attentive and followed all instructions during the more critical phases of voir dire, the trial, and deliberations, and was therefore able to serve as an unbiased juror.

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 page is from a court order (Case 1:20-cr-00330-PAE, likely *US v. Maxwell*) denying the Defendant's request to subpoena social media companies for Juror 50's communications. The Court rules that the request is a 'fishing expedition' and procedurally improper under the Stored Communications Act (SCA), which generally prohibits private parties (like the Defendant) from subpoenaing content from providers like Facebook or Instagram; only the Government may do so with a warrant.

This document is page 39 of a government legal filing (Document 643) in the case against Ghislaine Maxwell (Case 1:20-cr-00330). The prosecution argues against the defendant's motion to call all twelve jurors as witnesses to investigate potential non-disclosure of sexual abuse, labeling it a 'fishing expedition' damaging to the jury process. The text specifically addresses a New York Times article mentioning a second juror's abuse history and argues that questioning should be strictly limited to Juror 50.

This document is page 2 of a legal filing (Document 617) in Case 1:20-cr-00330 (USA v. Ghislaine Maxwell), filed on February 24, 2022. The text argues against the defendant's claim that 'Juror 50's' motion to intervene constitutes a discovery request, clarifying that the juror is seeking access to his own questionnaire which he swore under penalty of perjury. The filing argues that the motion is a judicial document that should not remain sealed, noting the defendant's arguments regarding privacy and potential prejudice lack merit.

This document is page 30 of a court filing (Case 1:20-cr-00330-PAE) filed on Feb 24, 2022. It discusses the defendant's argument that Juror 50 displayed implied bias by allegedly lying, rejecting comparisons to the 'Daugerdas' case and the dismissal of Juror 55. The court concludes that the defendant failed to establish implied bias, with significant portions of the text regarding Juror 55 redacted.

This document is Page 43 of a legal filing (Document 615) in Case 1:20-cr-00330 (USA v. Ghislaine Maxwell), filed on February 24, 2022. The text argues against the defendant's request to compel the production of 'Juror 50's' (Scotty David) private emails and social media records (Facebook, Twitter, LinkedIn, Instagram). The prosecution characterizes the defense's request as an inadmissible 'fishing expedition' and argues that the juror's post-trial media interviews or comments on a victim's Twitter post do not justify invading his privacy regarding pre-trial or during-trial communications.

This document is page 20 of a court filing (Document 615) from the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on February 24, 2022. The text argues against the defendant's claim that 'Juror 50' deliberately lied on a jury questionnaire regarding past victimization, suggesting that laypersons may not classify their own abuse as a 'crime' in the same way legal professionals do. A significant portion of the page following this argument is heavily redacted.