{
  "document_metadata": {
    "page_number": "19 of 49",
    "document_number": "643",
    "date": "03/11/22",
    "document_type": "court document",
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  "full_text": "Case 1:20-cr-00330-PAE Document 643 Filed 03/11/22 Page 19 of 49\nwhich are relatively easily understood by lawyers and judges.\"); Dyer v. Calderon, 151 F.3d 970, 973 (9th Cir. 1998) (“[W]e must be tolerant, as jurors may forget incidents long buried in their minds, misunderstand a question or bend the truth a bit to avoid embarrassment.”); United States v. Fell, No. 01 Cr. 12, 2014 WL 3697810, at *13 (D. Vt. July 24, 2014) (“[T]he written juror questionnaires must be viewed in context. The long questionnaire in particular consisted of 75 questions not including sub-parts.”).11 And, in any event, the credibility of Juror 50’s explanation as to why, if he was indeed a victim of sexual abuse, he answered this question in the negative is properly resolved not based on a review of unsworn public statements, but at a hearing at which the Court can question him on this subject and assess his credibility.\nFurthermore, the defendant’s suggestion that Juror 50 deliberately lied in order to serve on the jury is undermined by several aspects of Juror 50’s conduct. For example, when answering the questions about exposure to pretrial publicity, Juror 50 disclosed that he had read about the defendant and her connection to Epstein. If a juror was willing to lie about sexual abuse to ensure that he was seated on the jury, he would, presumably, have lied about other potentially disqualifying facts, too. Similarly, if Juror 50 deliberately lied under penalty of perjury in order to serve on the jury, it would make little sense for him to immediately publicize that fact, thus exposing himself to criminal liability. See Perez, 1997 WL 403458, at *6 (“I find it improbable that a juror who lied on voir dire in order to be empaneled on a jury in an age discrimination case to avenge himself against a discriminatory employer who was not a party to the lawsuit would reveal this motivation after rendering a verdict. If this had been the juror’s intent, there was no reason why he would expose himself to defense counsel immediately following the verdict.”).\n11 Indeed, Juror 50’s counsel, in his motion to intervene, discussed infra at Part III, wrote that Juror 50 “does not recall answering questions [in the questionnaire] regarding his prior experience with sexual assault.” (Juror 50 Mem. at 5).\n17\nDOJ-OGR-00009817",
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      "content": "Case 1:20-cr-00330-PAE Document 643 Filed 03/11/22 Page 19 of 49",
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    {
      "type": "printed",
      "content": "which are relatively easily understood by lawyers and judges.\"); Dyer v. Calderon, 151 F.3d 970, 973 (9th Cir. 1998) (“[W]e must be tolerant, as jurors may forget incidents long buried in their minds, misunderstand a question or bend the truth a bit to avoid embarrassment.”); United States v. Fell, No. 01 Cr. 12, 2014 WL 3697810, at *13 (D. Vt. July 24, 2014) (“[T]he written juror questionnaires must be viewed in context. The long questionnaire in particular consisted of 75 questions not including sub-parts.”).11 And, in any event, the credibility of Juror 50’s explanation as to why, if he was indeed a victim of sexual abuse, he answered this question in the negative is properly resolved not based on a review of unsworn public statements, but at a hearing at which the Court can question him on this subject and assess his credibility.",
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    {
      "type": "printed",
      "content": "Furthermore, the defendant’s suggestion that Juror 50 deliberately lied in order to serve on the jury is undermined by several aspects of Juror 50’s conduct. For example, when answering the questions about exposure to pretrial publicity, Juror 50 disclosed that he had read about the defendant and her connection to Epstein. If a juror was willing to lie about sexual abuse to ensure that he was seated on the jury, he would, presumably, have lied about other potentially disqualifying facts, too. Similarly, if Juror 50 deliberately lied under penalty of perjury in order to serve on the jury, it would make little sense for him to immediately publicize that fact, thus exposing himself to criminal liability. See Perez, 1997 WL 403458, at *6 (“I find it improbable that a juror who lied on voir dire in order to be empaneled on a jury in an age discrimination case to avenge himself against a discriminatory employer who was not a party to the lawsuit would reveal this motivation after rendering a verdict. If this had been the juror’s intent, there was no reason why he would expose himself to defense counsel immediately following the verdict.”).",
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    {
      "type": "printed",
      "content": "11 Indeed, Juror 50’s counsel, in his motion to intervene, discussed infra at Part III, wrote that Juror 50 “does not recall answering questions [in the questionnaire] regarding his prior experience with sexual assault.” (Juror 50 Mem. at 5).",
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      "content": "17",
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      "content": "DOJ-OGR-00009817",
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  "entities": {
    "people": [
      "Juror 50",
      "Epstein"
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    "organizations": [
      "Court",
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    "locations": [
      "D. Vt."
    ],
    "dates": [
      "03/11/22",
      "July 24, 2014"
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    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 643",
      "DOJ-OGR-00009817"
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  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
}