{
  "document_metadata": {
    "page_number": "58",
    "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 58 of 66\nclaim. See Cunningham v. Shoop, __ F.4th __, 2022 WL 92594, at *14-15 (6th Cir. Nos. 11-3005/20-3429, Jan. 10, 2022) (granting habeas relief as to juror bias claim because it is \"possible for Cunningham to prove that [the juror] was actually biased without relying on juror testimony in violation of Federal Rule of Evidence 606(b)\"); compare Pena-Rodriguez v. Colorado, 137 S. Ct. 855 (2017) (\"Where a juror makes a clear statement indicating that he or she relied on racial stereotypes or animus to convict a criminal defendant, the Sixth Amendment requires that the no-impeachment rule give way in order to permit the trial court to consider the evidence of the juror's statement and any resulting denial of the jury trial guarantee.\") Without relying on juror testimony, it is already clear that Juror No. 50 did not truthfully answer the questionnaire; Juror No. 50 has publicly admitted he is a victim of sexual assault and sexual abuse.\nAs for identifying the other juror who was also a victim of sexual assault and abuse, the Court and parties can identify the juror without eliciting testimony about what was said during deliberations. The remaining eleven jurors can be asked, under oath, whether their answer to question 48 is correct and whether they have been a victim of sexual assault or abuse. Presumably the second juror will self-identify.\nIII. Juror No. 50 has no right to intervene.\nA. Juror No. 50 lacks standing.\nJuror No. 50 seeks to intervene suggesting that \"it is indisputable that precedent supports intervention by interested third parties in criminal matters....\" Memo. at 8. This claim is not supported by \"the long line of precedent hold[ing] that a non-party lacks a judicially cognizable interest in a defendant's prosecution.\" United States v. Stoerr, 695\n51\nDOJ-OGR-00009750",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 58 of 66",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "claim. See Cunningham v. Shoop, __ F.4th __, 2022 WL 92594, at *14-15 (6th Cir. Nos. 11-3005/20-3429, Jan. 10, 2022) (granting habeas relief as to juror bias claim because it is \"possible for Cunningham to prove that [the juror] was actually biased without relying on juror testimony in violation of Federal Rule of Evidence 606(b)\"); compare Pena-Rodriguez v. Colorado, 137 S. Ct. 855 (2017) (\"Where a juror makes a clear statement indicating that he or she relied on racial stereotypes or animus to convict a criminal defendant, the Sixth Amendment requires that the no-impeachment rule give way in order to permit the trial court to consider the evidence of the juror's statement and any resulting denial of the jury trial guarantee.\") Without relying on juror testimony, it is already clear that Juror No. 50 did not truthfully answer the questionnaire; Juror No. 50 has publicly admitted he is a victim of sexual assault and sexual abuse.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "As for identifying the other juror who was also a victim of sexual assault and abuse, the Court and parties can identify the juror without eliciting testimony about what was said during deliberations. The remaining eleven jurors can be asked, under oath, whether their answer to question 48 is correct and whether they have been a victim of sexual assault or abuse. Presumably the second juror will self-identify.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "III. Juror No. 50 has no right to intervene.\nA. Juror No. 50 lacks standing.\nJuror No. 50 seeks to intervene suggesting that \"it is indisputable that precedent supports intervention by interested third parties in criminal matters....\" Memo. at 8. This claim is not supported by \"the long line of precedent hold[ing] that a non-party lacks a judicially cognizable interest in a defendant's prosecution.\" United States v. Stoerr, 695",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "51",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00009750",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Cunningham",
      "Shoop",
      "Pena-Rodriguez",
      "Stoerr"
    ],
    "organizations": [
      "Court",
      "Sixth Amendment"
    ],
    "locations": [],
    "dates": [
      "Jan. 10, 2022",
      "03/11/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 642",
      "11-3005/20-3429",
      "695",
      "DOJ-OGR-00009750"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, discussing juror bias and the right to intervene. The text is printed and there are no visible stamps or handwritten notes. The document is page 58 of 66."
}