{
  "document_metadata": {
    "page_number": "27 of 32",
    "document_number": "644",
    "date": "03/11/22",
    "document_type": "court document",
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  "full_text": "Case 1:20-cr-00330-PAE Document 644 Filed 03/11/22 Page 27 of 32\n\n.10 The government therefore wants Juror No. 50 to only now correctly answer Question 48 but not give the details as he would have had to do in Question 48a in the event he had correctly answered Question 48 at the time of voir dire. The government also misses the significant point that none of these other jurors disclosed childhood sexual abuse, the facts underlying the charges in this case.\n\nThe government also mischaracterizes the record regarding questions to - and potential for cause challenges against -any juror who may have been incapable of accepting the testimony of Ms. Maxwell's expert, Dr. Loftus. See Resp. at 35-36. The government first only points to the fact that none of the jurors who answered yes to Question 48 were asked about the expert testimony. That is because none of the others - like Juror No. 50 - claimed to have been the victim of childhood sexual abuse, i.e., the charges in this case. Why would anyone have asked whether a groping on the subway as an adult would be replayed like a videotape? Second, this Court inquired of many other potential jurors, including at the request of the government, whether they could put aside their outside knowledge and consider the expert testimony presented at trial. See, e.g., Tr. 489-90, 527-28, 534-39, 666-67, 709-10. There is nothing to suggest that, had Juror No. 50 disclosed his beliefs about the science of memory as he publicly aired post-verdict in the media (that his own memory is like a video-tape), that the Court would not have followed up to inquire whether he could fairly evaluate expert testimony on that topic.\n\n10 The other jurors who also answered affirmatively to question 48 provided the details, as required by the questionnaire, to 48a. See generally Resp. at 4-5;\n\n22\nDOJ-OGR-00009896",
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      "content": "Case 1:20-cr-00330-PAE Document 644 Filed 03/11/22 Page 27 of 32",
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      "content": ".10 The government therefore wants Juror No. 50 to only now correctly answer Question 48 but not give the details as he would have had to do in Question 48a in the event he had correctly answered Question 48 at the time of voir dire. The government also misses the significant point that none of these other jurors disclosed childhood sexual abuse, the facts underlying the charges in this case.",
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      "content": "The government also mischaracterizes the record regarding questions to - and potential for cause challenges against -any juror who may have been incapable of accepting the testimony of Ms. Maxwell's expert, Dr. Loftus. See Resp. at 35-36. The government first only points to the fact that none of the jurors who answered yes to Question 48 were asked about the expert testimony. That is because none of the others - like Juror No. 50 - claimed to have been the victim of childhood sexual abuse, i.e., the charges in this case. Why would anyone have asked whether a groping on the subway as an adult would be replayed like a videotape? Second, this Court inquired of many other potential jurors, including at the request of the government, whether they could put aside their outside knowledge and consider the expert testimony presented at trial. See, e.g., Tr. 489-90, 527-28, 534-39, 666-67, 709-10. There is nothing to suggest that, had Juror No. 50 disclosed his beliefs about the science of memory as he publicly aired post-verdict in the media (that his own memory is like a video-tape), that the Court would not have followed up to inquire whether he could fairly evaluate expert testimony on that topic.",
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      "type": "printed",
      "content": "10 The other jurors who also answered affirmatively to question 48 provided the details, as required by the questionnaire, to 48a. See generally Resp. at 4-5;",
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      "content": "22",
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      "content": "DOJ-OGR-00009896",
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  "entities": {
    "people": [
      "Juror No. 50",
      "Ms. Maxwell",
      "Dr. Loftus"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "03/11/22"
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    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 644",
      "DOJ-OGR-00009896"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 27 of 32."
}