{
  "document_metadata": {
    "page_number": "9",
    "document_number": "648",
    "date": "03/15/22",
    "document_type": "court document",
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  "full_text": "Case 1:20-cr-00330-PAE Document 648 Filed 03/15/22 Page 9 of 16\n\nQuestion 49 was not precisely accurate, as he freely acknowledged at the hearing. But, as he explained, at the time he completed the questionnaire, it did not occur to him that his own abuse required an affirmative answer. (Mar. 8, 2022 Tr. at 11:25). And when asked during the hearing, his initial answer reflected an honest and reasonable understanding of the question: he answered no because he did not consider his former stepbrother, who he never considered to be part of his family, as a family member. See United States v. Stewart, 317 F. Supp. 2d 432, 438 (S.D.N.Y. 2004) (“Would a reasonable juror necessarily consider an ex-girlfriend to be ‘someone close to him?’”), aff’d, 433 F.3d 273 (2d Cir. 2006). It was only once the Court focused his attention on the literal meaning of the question that he realized a different answer was accurate. Juror 50’s answers on this score bespeak a lack of linguistic precision, not a lack of credibility.\n\nJurors can and do make mistakes, and a defendant is entitled to fairness, not perfection. See McDonough, 464 U.S. at 553-55 (“This Court has long held that [a litigant] is entitled to a fair trial but not a perfect one, for there are no perfect trials. . . . To invalidate the result of a three-week trial because of a juror’s mistaken, though honest response to a question, is to insist on something closer to perfection than our judicial system can be expected to give.”) (alteration in original, internal quotation marks omitted)). It is clear that Juror 50 made a mistake from a failure to be careful, and not a desire to get on the jury. Juror 50 repeatedly and consistently testified under oath that he did not try to get on the jury. In response to questioning by the Court, Juror 50 explained, without hesitation, that he “did not hope to be on this jury” and that he “did not set out in order to get on this jury.”3 (Mar. 8, 2022 Tr. at 14:2-5). He did not even know what case he\n\n3 Nothing about this argument is undermined by Juror 50’s comment that “if you’re going to serve jury duty, it might as well [ ] be something that’s interesting.” (Mar. 8, 2022 Tr. at 14:2-4). To the contrary, that comment demonstrates Juror 50’s candor at the hearing. Juror 50 said that if he had to serve jury duty, this case was “something interesting” when compared to more boring cases. (Id. at 44:8-11; see id. at 44:6 (“So not everybody gets called for jury duty.”)). Surely every\n\n7\nDOJ-OGR-00010299",
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      "content": "Case 1:20-cr-00330-PAE Document 648 Filed 03/15/22 Page 9 of 16",
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      "content": "Question 49 was not precisely accurate, as he freely acknowledged at the hearing. But, as he explained, at the time he completed the questionnaire, it did not occur to him that his own abuse required an affirmative answer. (Mar. 8, 2022 Tr. at 11:25). And when asked during the hearing, his initial answer reflected an honest and reasonable understanding of the question: he answered no because he did not consider his former stepbrother, who he never considered to be part of his family, as a family member. See United States v. Stewart, 317 F. Supp. 2d 432, 438 (S.D.N.Y. 2004) (“Would a reasonable juror necessarily consider an ex-girlfriend to be ‘someone close to him?’”), aff’d, 433 F.3d 273 (2d Cir. 2006). It was only once the Court focused his attention on the literal meaning of the question that he realized a different answer was accurate. Juror 50’s answers on this score bespeak a lack of linguistic precision, not a lack of credibility.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Jurors can and do make mistakes, and a defendant is entitled to fairness, not perfection. See McDonough, 464 U.S. at 553-55 (“This Court has long held that [a litigant] is entitled to a fair trial but not a perfect one, for there are no perfect trials. . . . To invalidate the result of a three-week trial because of a juror’s mistaken, though honest response to a question, is to insist on something closer to perfection than our judicial system can be expected to give.”) (alteration in original, internal quotation marks omitted)). It is clear that Juror 50 made a mistake from a failure to be careful, and not a desire to get on the jury. Juror 50 repeatedly and consistently testified under oath that he did not try to get on the jury. In response to questioning by the Court, Juror 50 explained, without hesitation, that he “did not hope to be on this jury” and that he “did not set out in order to get on this jury.”3 (Mar. 8, 2022 Tr. at 14:2-5). He did not even know what case he",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3 Nothing about this argument is undermined by Juror 50’s comment that “if you’re going to serve jury duty, it might as well [ ] be something that’s interesting.” (Mar. 8, 2022 Tr. at 14:2-4). To the contrary, that comment demonstrates Juror 50’s candor at the hearing. Juror 50 said that if he had to serve jury duty, this case was “something interesting” when compared to more boring cases. (Id. at 44:8-11; see id. at 44:6 (“So not everybody gets called for jury duty.”)). Surely every",
      "position": "bottom"
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    {
      "type": "printed",
      "content": "7",
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    {
      "type": "printed",
      "content": "DOJ-OGR-00010299",
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  ],
  "entities": {
    "people": [],
    "organizations": [],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "Mar. 8, 2022",
      "03/15/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "648",
      "317 F. Supp. 2d 432",
      "433 F.3d 273",
      "464 U.S.",
      "DOJ-OGR-00010299"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal brief, discussing the credibility of Juror 50 and the implications of their responses during a hearing. The text is well-formatted and mostly free of errors, suggesting a high-quality document."
}