{
  "document_metadata": {
    "page_number": "2",
    "document_number": "407",
    "date": "11/03/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 407 Filed 11/03/21 Page 2 of 7\nLAW OFFICES OF BOBBI C. STERNHEIM\n\nStates District Court for the Western District of Virginia ordered a semi-anonymous jury (jurors were publicly referred to by number only) and released the names of all potential jurors to counsel, plus all pro se defendants (including Richard Spencer and Christopher Cantwell), who are allegedly prominent white supremacists, neo-Nazis, and the leaders of hate groups that planned, promoted, and executed the violent acts in Charlottesville. (See Exhibit A, annexed.)\n\nThe defendants in Sines included factions of the Ku Klux Klan. The concerns for juror privacy in Sines dwarf any conceivable concerns in this case and Sines is also the subject of extensive ongoing publicity. We submit that withholding the names of 600 jurors until the day of jury selection will deprive Ms. Maxwell of her right to be tried by a fair and impartial jury and is a procedure that would violate due process in this particular case.1\n\n\"An impartial jury is one in which all of its members, not just most of them, are free of interest and bias.\" United States v. Parse, 789 F.3d 83, 111 (2d Cir. 2015). In Parse, a case before Judge Pauley sub nom United States v. Daugerdas, a jury convicted defendant Parse and three of his co-defendants of numerous financial fraud and tax evasion charges. 789 F.3d at 86.\n\nAfter trial, all defendants moved pursuant to Fed.R.Crim.P. 33(a) for a new trial on the ground that one of the jurors, Juror No. 1 (Catherine M. Conrad), \"had lied and withheld material information during voir dire and was biased against defendants. Judge Pauley appointed Bobbi C. Sternheim, Esq. to represent the juror and conducted an evidentiary hearing in which the juror was examined, and in a detailed thorough opinion (see United States v. Daugerdas, 867 F.Supp.2d 445 (S.D.N.Y.2012) found it \"undisputed that Conrad lied extensively during voir dire and concealed important information about her background\" (id. at 451), her level of education, place of residence, criminal history, and other matters. Parse, 789 F.3d at 87-90.\n\n1 We are unaware of any other recent high-profile case in which a written juror questionnaire was used and the Court withheld the names of the jurors from counsel following the completion of the questionnaires.\n\n2\nDOJ-OGR-00006050",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 407 Filed 11/03/21 Page 2 of 7",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "States District Court for the Western District of Virginia ordered a semi-anonymous jury (jurors were publicly referred to by number only) and released the names of all potential jurors to counsel, plus all pro se defendants (including Richard Spencer and Christopher Cantwell), who are allegedly prominent white supremacists, neo-Nazis, and the leaders of hate groups that planned, promoted, and executed the violent acts in Charlottesville. (See Exhibit A, annexed.)",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The defendants in Sines included factions of the Ku Klux Klan. The concerns for juror privacy in Sines dwarf any conceivable concerns in this case and Sines is also the subject of extensive ongoing publicity. We submit that withholding the names of 600 jurors until the day of jury selection will deprive Ms. Maxwell of her right to be tried by a fair and impartial jury and is a procedure that would violate due process in this particular case.1",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "\"An impartial jury is one in which all of its members, not just most of them, are free of interest and bias.\" United States v. Parse, 789 F.3d 83, 111 (2d Cir. 2015). In Parse, a case before Judge Pauley sub nom United States v. Daugerdas, a jury convicted defendant Parse and three of his co-defendants of numerous financial fraud and tax evasion charges. 789 F.3d at 86.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "After trial, all defendants moved pursuant to Fed.R.Crim.P. 33(a) for a new trial on the ground that one of the jurors, Juror No. 1 (Catherine M. Conrad), \"had lied and withheld material information during voir dire and was biased against defendants. Judge Pauley appointed Bobbi C. Sternheim, Esq. to represent the juror and conducted an evidentiary hearing in which the juror was examined, and in a detailed thorough opinion (see United States v. Daugerdas, 867 F.Supp.2d 445 (S.D.N.Y.2012) found it \"undisputed that Conrad lied extensively during voir dire and concealed important information about her background\" (id. at 451), her level of education, place of residence, criminal history, and other matters. Parse, 789 F.3d at 87-90.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "1 We are unaware of any other recent high-profile case in which a written juror questionnaire was used and the Court withheld the names of the jurors from counsel following the completion of the questionnaires.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006050",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Richard Spencer",
      "Christopher Cantwell",
      "Ms. Maxwell",
      "Catherine M. Conrad",
      "Bobbi C. Sternheim",
      "Judge Pauley"
    ],
    "organizations": [
      "Ku Klux Klan",
      "Law Offices of Bobbi C. Sternheim"
    ],
    "locations": [
      "Western District of Virginia",
      "Charlottesville",
      "S.D.N.Y"
    ],
    "dates": [
      "11/03/21",
      "2015",
      "2012"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 407",
      "789 F.3d 83",
      "867 F.Supp.2d 445",
      "DOJ-OGR-00006050"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a high-profile case. The text is well-formatted and printed, with no visible handwriting or stamps. The document includes citations to legal cases and references to specific court rules."
}