{
  "document_metadata": {
    "page_number": "64 of 66",
    "document_number": "613",
    "date": "02/24/22",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 613 Filed 02/24/22 Page 64 of 66\n\nFor its part, this Court expressed “confidence” that its voir dire process would “smoke out” a juror who was dishonest. Ms. Maxwell relied on the Court’s process. And the Court and the parties relied on the presumption to which everyone is entitled: that potential jurors would carefully and honestly engage in voir dire.\n\nUnfortunately, we now know that Juror No. 50 (and at least one other juror) did not honor their obligations to give “only truthful answers.” Ex. 1, p 3. They are no longer entitled to the presumption of honesty.\n\nBecause Ms. Maxwell’s jury was not the fair and impartial one guaranteed her by the United States Constitution, this Court should vacate the jury’s verdict and order a new trial. In the alternative, this Court should hold an evidentiary hearing and examine all twelve jurors.\n\nDated: January 19, 2022\n\n57\nDOJ-OGR-00009065",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 613 Filed 02/24/22 Page 64 of 66",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "For its part, this Court expressed “confidence” that its voir dire process would “smoke out” a juror who was dishonest. Ms. Maxwell relied on the Court’s process. And the Court and the parties relied on the presumption to which everyone is entitled: that potential jurors would carefully and honestly engage in voir dire.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Unfortunately, we now know that Juror No. 50 (and at least one other juror) did not honor their obligations to give “only truthful answers.” Ex. 1, p 3. They are no longer entitled to the presumption of honesty.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Because Ms. Maxwell’s jury was not the fair and impartial one guaranteed her by the United States Constitution, this Court should vacate the jury’s verdict and order a new trial. In the alternative, this Court should hold an evidentiary hearing and examine all twelve jurors.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dated: January 19, 2022",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "57",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00009065",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [],
    "locations": [
      "United States"
    ],
    "dates": [
      "January 19, 2022",
      "02/24/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 613",
      "Ex. 1",
      "DOJ-OGR-00009065"
    ]
  },
  "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 64 of 66."
}