{
  "document_metadata": {
    "page_number": "1",
    "document_number": "570",
    "date": "January 5, 2022",
    "document_type": "Letter",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 570 Filed 01/05/22 Page 1 of 3\nHaddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagliuca@hmflaw.com January 5, 2022 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, I write in response to the government's letter of this morning requesting a hearing to consider a Juror's statements to various media sources that the Juror was a victim of sexual assault. Doc. 568. The government's request for a hearing is premature because based on undisputed, publicly available information, the Court can and should order a new trial without any evidentiary hearing. The Supreme Court has held that to be entitled to a new trial, \"a party must first demonstrate that a juror failed to answer honestly a material question on voir dire, and then further show that a correct response would have provided a valid basis for a challenge for cause. McDonough Power Equip., Inc. v. Greenwood, 464 U.S. 548, 556 (1984). This standard applies even if the juror's conduct was merely inadvertent and not intentional. United States v. Langford, 990 F.2d 65, 68 (2d Cir. 1993) (\"We read [the McDonough] multi-part test as governing not only inadvertent nondisclosures but also nondisclosures or misstatements that were deliberate.\"). DOJ-OGR-00008804",
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      "content": "Case 1:20-cr-00330-PAE Document 570 Filed 01/05/22 Page 1 of 3",
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    {
      "type": "printed",
      "content": "Haddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagliuca@hmflaw.com",
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    {
      "type": "printed",
      "content": "January 5, 2022",
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    {
      "type": "printed",
      "content": "VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan,",
      "position": "top"
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    {
      "type": "printed",
      "content": "I write in response to the government's letter of this morning requesting a hearing to consider a Juror's statements to various media sources that the Juror was a victim of sexual assault. Doc. 568. The government's request for a hearing is premature because based on undisputed, publicly available information, the Court can and should order a new trial without any evidentiary hearing.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Supreme Court has held that to be entitled to a new trial, \"a party must first demonstrate that a juror failed to answer honestly a material question on voir dire, and then further show that a correct response would have provided a valid basis for a challenge for cause. McDonough Power Equip., Inc. v. Greenwood, 464 U.S. 548, 556 (1984). This standard applies even if the juror's conduct was merely inadvertent and not intentional. United States v. Langford, 990 F.2d 65, 68 (2d Cir. 1993) (\"We read [the McDonough] multi-part test as governing not only inadvertent nondisclosures but also nondisclosures or misstatements that were deliberate.\").",
      "position": "middle"
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    {
      "type": "printed",
      "content": "DOJ-OGR-00008804",
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  "entities": {
    "people": [
      "Jeffrey S. Pagliuca",
      "Alison J. Nathan",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Southern District of New York",
      "Supreme Court"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "January 5, 2022",
      "1984",
      "1993"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 570",
      "20 Cr. 330 (AJN)",
      "Doc. 568",
      "464 U.S. 548",
      "990 F.2d 65"
    ]
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  "additional_notes": "The document appears to be a formal letter from a law firm to a judge, discussing a court case and referencing various legal precedents. The text is well-formatted and free of significant damage or redactions."
}