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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 arguing for the credibility of Juror 50 against a defendant's challenge. The filing contends that any inconsistencies in the juror's questionnaire answers should be assessed in a formal hearing, not based on public statements, and cites legal precedents suggesting jurors can make honest mistakes. It further argues that the juror's disclosure of having read about the defendant's connection to Epstein and the illogical nature of deliberately lying only to immediately risk exposure suggest the juror did not intentionally mislead the court.

This document is page 3 of a legal filing (Document 583) from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on January 25, 2022. It argues against the Defendant's request to delay public access to juror questionnaires, specifically citing the misconduct of 'Juror 50' as grounds for a new trial motion. The filing asserts that First Amendment rights and Second Circuit precedent (Lugosch) support immediate unsealing now that the trial has concluded.

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 is a portion of a court filing arguing against a defendant's motion. The defendant seeks to strike a motion to intervene filed by 'Juror 50', claiming it is inappropriate and not a 'judicial document' deserving public access. The author of this filing refutes these claims, arguing that the defendant's cited legal precedents are inapplicable and that Juror 50's motion is relevant to the judicial process and should not be struck.

This legal document is a court filing from February 25, 2022, detailing the court's denial of a defendant's request to subpoena social media companies for the communications of 'Juror 50'. The court rules the request is a speculative "fishing expedition" and is procedurally improper under the Stored Communications Act (SCA), which does not permit a defendant in a criminal case to subpoena such content directly from providers like Facebook or Instagram.

This legal document, part of case 1:20-cr-00330-PAE, argues that a juror, identified as Juror 50, did not deliberately lie on a questionnaire but rather made an "honest mistake." A hearing established that the juror was not biased, approached his service with an open mind, and would not have been dismissed for cause even if he had answered correctly. Therefore, the document concludes that the defendant's motion for relief based on the juror's alleged misconduct should be denied.

This legal document, part of case 22-1426, argues that the District Court abused its discretion during a post-trial hearing. The filing contends that the court improperly prevented the defense from cross-examining Juror 50, who, it is argued, would have been dismissed from the jury had he truthfully disclosed the nature of his past abuse during jury selection. The document contrasts the severe abuse suffered by Juror 50 with lesser forms of sexual assault reported by other potential jurors who were not dismissed.

This legal document, filed on February 25, 2022, details a court's order regarding an inquiry into the truthfulness of answers provided by Juror 50. The court sets a deadline of March 1, 2022, for the parties to submit proposed questions for a hearing. The court denies the Defendant's broad subpoena requests for Juror 50's communications, social media history, and other records, labeling them a "vexatious, intrusive, unjustified, and a fishing expedition."

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 is a court's analysis concluding that Juror 50 is neither impliedly nor inferably biased against the Defendant. The court reasons that the juror's personal experience of sexual abuse is insufficient to infer partiality and that, based on the voir dire of other jurors, it is unlikely the Defendant would have successfully challenged the juror for cause.

This legal document argues against a defendant's request to compel the production of private communications from 'Juror 50', including emails and social media content from platforms like Facebook and Twitter. The author contends that the requests are an improper and invasive 'fishing expedition' that seeks inadmissible evidence, would harass the juror, and could inhibit future jury deliberations. The document urges the Court to reject all of the defendant's specific requests for information regarding the juror's communications, potential media payments, and social media activity.

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 legal document is a court's analysis of a defendant's motion for a new trial. The defendant argues that Juror 50's failure to disclose a history of sexual abuse denied her the ability to use a peremptory challenge. The court distinguishes the applicable federal law (the McDonough standard) from the New Jersey state law cited by the defendant and begins its analysis of the first prong of the McDonough test, noting that Juror 50 did provide inaccurate answers on a questionnaire.

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 court order from case 1:20-cr-00330-PAE, filed on February 11, 2022. The Court denies two separate requests: first, it denies Juror 50's motion to intervene in the criminal case, and second, it denies the Defendant's requests to either strike or seal Juror 50's motion. The Court's reasoning relies on legal precedent, stating that motions to strike are disfavored and that Juror 50's motion qualifies as a judicial document subject to the presumption of public access.

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.