{
  "document_metadata": {
    "page_number": "3",
    "document_number": "648",
    "date": "03/15/22",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 648 Filed 03/15/22 Page 3 of 16\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n---------------------------------------------------------------X\n\nUNITED STATES OF AMERICA :\n-v.- : S2 20 Cr. 330 (AJN)\nGHISLAINE MAXWELL, :\nDefendant. :\n---------------------------------------------------------------X\n\nThe Government respectfully submits this memorandum in further support of its opposition to the defendant's motion for a new trial, dated January 19, 2022 (the \"Defense Motion\"). After the thoughtful and thorough hearing held by this Court, it is crystal clear that the defendant received a fair trial. Juror 50's sworn testimony at the hearing made evident that he did not deliberately lie in completing the questionnaire, but that he instead made an honest mistake. And in any event, had Juror 50 accurately reported in his questionnaire that he had been a victim of sexual abuse, he would not have been struck for cause. Juror 50 repeatedly explained—just as he did during voir dire—that he would be fair and impartial and would decide the case based on the evidence at trial and the law as explained by the Court. Accordingly, under controlling Supreme Court and Second Circuit precedent, the defendant cannot show that Juror 50 harbored any bias against the defendant. Moreover, during voir dire, multiple other potential jurors in this case reported having experienced sexual abuse and were nonetheless qualified as jurors without any objection from the defendant. It was entirely appropriate for Juror 50 to sit on this jury, and nothing about his service as a juror calls into question the integrity of the verdict in this case.\n\n1\nDOJ-OGR-00010293",
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      "content": "UNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n---------------------------------------------------------------X\n\nUNITED STATES OF AMERICA :\n-v.- : S2 20 Cr. 330 (AJN)\nGHISLAINE MAXWELL, :\nDefendant. :\n---------------------------------------------------------------X",
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    {
      "type": "printed",
      "content": "The Government respectfully submits this memorandum in further support of its opposition to the defendant's motion for a new trial, dated January 19, 2022 (the \"Defense Motion\"). After the thoughtful and thorough hearing held by this Court, it is crystal clear that the defendant received a fair trial. Juror 50's sworn testimony at the hearing made evident that he did not deliberately lie in completing the questionnaire, but that he instead made an honest mistake. And in any event, had Juror 50 accurately reported in his questionnaire that he had been a victim of sexual abuse, he would not have been struck for cause. Juror 50 repeatedly explained—just as he did during voir dire—that he would be fair and impartial and would decide the case based on the evidence at trial and the law as explained by the Court. Accordingly, under controlling Supreme Court and Second Circuit precedent, the defendant cannot show that Juror 50 harbored any bias against the defendant. Moreover, during voir dire, multiple other potential jurors in this case reported having experienced sexual abuse and were nonetheless qualified as jurors without any objection from the defendant. It was entirely appropriate for Juror 50 to sit on this jury, and nothing about his service as a juror calls into question the integrity of the verdict in this case.",
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      "type": "printed",
      "content": "DOJ-OGR-00010293",
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  ],
  "entities": {
    "people": [
      "GHISLAINE MAXWELL",
      "Juror 50"
    ],
    "organizations": [
      "UNITED STATES DISTRICT COURT",
      "UNITED STATES OF AMERICA",
      "Supreme Court",
      "Second Circuit"
    ],
    "locations": [
      "NEW YORK"
    ],
    "dates": [
      "January 19, 2022",
      "03/15/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "S2 20 Cr. 330 (AJN)",
      "648",
      "DOJ-OGR-00010293"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ghislaine Maxwell. The text is well-formatted and clear, with no visible redactions or damage."
}