{
  "document_metadata": {
    "page_number": "35",
    "document_number": "642",
    "date": "03/11/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 35 of 66\n2d at 468 (quoting Dyer v. Calderon, 151 F.3d 970, 983 (9th Cir.1998) (en banc)).\n\"[C]ourts cannot administer justice in circumstances in which a juror can commit a federal crime in order to serve as a juror in a criminal case and do so with no fear of sanction so long as a conviction results.\" United States v. Colombo, 869 F.2d 149, 152 (2d Cir. 1989).\n\nArgument\nI. Ms. Maxwell is entitled to a new trial.\nThis Court must order a new trial if Ms. Maxwell can make two showings: First, that Juror No. 50's voir dire response was false and second, that the correct response would have provided a valid basis for a challenge for cause. Stewart, 433 F.3d at 303. Even without an evidentiary hearing, Ms. Maxwell has made that showing here.\nA. Juror No. 50 did not truthfully answer material questions during voir dire, including Questions 25 and 48.\nThere is no reasonable dispute that Juror No. 50's voir dire responses were false. Juror No. 50 has told several media outlets that he was a victim of sexual assault and sexual abuse as a child. Necessarily, then, Juror No. 50 did not provide truthful answers when he denied being the victim of a crime (Question 25) or being a victim of sexual harassment, sexual abuse, or sexual assault (Question 48).\nAnd because being a victim of sexual assault or sexual abuse is material to an individual's ability to serve as a fair and impartial juror in a case about sexual assault and sexual abuse, Ms. Maxwell has satisfied the first prong of the McDonough test. See United States v. Sampson, 820 F. Supp. 2d 151, 172 (D. Mass. 2011) (\"[A] matter is\n28\nDOJ-OGR-00009727",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 35 of 66",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "2d at 468 (quoting Dyer v. Calderon, 151 F.3d 970, 983 (9th Cir.1998) (en banc)).\n\"[C]ourts cannot administer justice in circumstances in which a juror can commit a federal crime in order to serve as a juror in a criminal case and do so with no fear of sanction so long as a conviction results.\" United States v. Colombo, 869 F.2d 149, 152 (2d Cir. 1989).\n\nArgument\nI. Ms. Maxwell is entitled to a new trial.\nThis Court must order a new trial if Ms. Maxwell can make two showings: First, that Juror No. 50's voir dire response was false and second, that the correct response would have provided a valid basis for a challenge for cause. Stewart, 433 F.3d at 303. Even without an evidentiary hearing, Ms. Maxwell has made that showing here.\nA. Juror No. 50 did not truthfully answer material questions during voir dire, including Questions 25 and 48.\nThere is no reasonable dispute that Juror No. 50's voir dire responses were false. Juror No. 50 has told several media outlets that he was a victim of sexual assault and sexual abuse as a child. Necessarily, then, Juror No. 50 did not provide truthful answers when he denied being the victim of a crime (Question 25) or being a victim of sexual harassment, sexual abuse, or sexual assault (Question 48).\nAnd because being a victim of sexual assault or sexual abuse is material to an individual's ability to serve as a fair and impartial juror in a case about sexual assault and sexual abuse, Ms. Maxwell has satisfied the first prong of the McDonough test. See United States v. Sampson, 820 F. Supp. 2d 151, 172 (D. Mass. 2011) (\"[A] matter is",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "28",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00009727",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Dyer",
      "Calderon",
      "Colombo",
      "Stewart",
      "Sampson",
      "McDonough"
    ],
    "organizations": [
      "United States"
    ],
    "locations": [
      "Massachusetts"
    ],
    "dates": [
      "03/11/22",
      "1989",
      "1998",
      "2011"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 642",
      "DOJ-OGR-00009727"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 35 of 66."
}