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  "document_metadata": {
    "page_number": "41",
    "document_number": "643",
    "date": "03/11/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 643 Filed 03/11/22 Page 41 of 49\naffirmed, holding that “the unsworn, uncorroborated statements that one unidentified juror made to a magazine reporter do not constitute the ‘clear, strong, substantial and incontrovertible evidence’ requiring any juror inquiry beyond that already made.” Guzman Loera, 2022 WL 211199, at *12 (quoting Moon, 718 F.2d at 1234). The same is true here: a newspaper report about an anonymous juror who had experienced sexual abuse is not “incontrovertible evidence” that juror misconduct occurred.\n\nSimilarly, in United States v. Bin Laden, one defendant sought a new trial based on a sentence in a newspaper article, which, based on interviews with jurors, stated that “[o]ne juror used the internet at home to research a difficult legal concept concerning [one] defendant.” The district court declined to hold an evidentiary hearing, holding that “[t]his single sentence, an unsworn snippet of hearsay within a newspaper article, is far less substantial than the sworn affidavits present in cases where evidentiary hearings have been ordered.” United States v. Bin Laden, No. S7R 98 Cr. 1023 (KTD), 2005 WL 287404, at *2 (S.D.N.Y. Feb. 7, 2005), aff’d sub nom. In re Terrorist Bombings of U.S. Embassies in E. Afr., 552 F.3d 93 (2d Cir. 2008).\n\nFinally, in Martha Stewart, the defendant brought a post-trial motion alleging a host of deliberate omissions by a juror. 317 F. Supp. 2d at 438. Among the alleged deliberate omissions was that the juror had been fired from his job at Citibank for abusing drugs or improper expense accounting. Id. at 442. The district court denied a hearing with regard to this (and the other) allegations, as it was based on (a) statements of an individual who “appears to be reporting rumors,” and (b) an anonymous call to the defendant’s lawyer from an individual purporting to work for Citibank. Id. The Second Circuit affirmed that decision, noting that the defendant’s factual proffer as to this (and certain other) allegations was “insufficient.” Stewart, 433 F.3d at 305 & n.7. And although the Second Circuit stated in dicta that it might have held a hearing in the\n39\nDOJ-OGR-00009839",
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      "content": "Case 1:20-cr-00330-PAE Document 643 Filed 03/11/22 Page 41 of 49",
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    {
      "type": "printed",
      "content": "affirmed, holding that “the unsworn, uncorroborated statements that one unidentified juror made to a magazine reporter do not constitute the ‘clear, strong, substantial and incontrovertible evidence’ requiring any juror inquiry beyond that already made.” Guzman Loera, 2022 WL 211199, at *12 (quoting Moon, 718 F.2d at 1234). The same is true here: a newspaper report about an anonymous juror who had experienced sexual abuse is not “incontrovertible evidence” that juror misconduct occurred.\n\nSimilarly, in United States v. Bin Laden, one defendant sought a new trial based on a sentence in a newspaper article, which, based on interviews with jurors, stated that “[o]ne juror used the internet at home to research a difficult legal concept concerning [one] defendant.” The district court declined to hold an evidentiary hearing, holding that “[t]his single sentence, an unsworn snippet of hearsay within a newspaper article, is far less substantial than the sworn affidavits present in cases where evidentiary hearings have been ordered.” United States v. Bin Laden, No. S7R 98 Cr. 1023 (KTD), 2005 WL 287404, at *2 (S.D.N.Y. Feb. 7, 2005), aff’d sub nom. In re Terrorist Bombings of U.S. Embassies in E. Afr., 552 F.3d 93 (2d Cir. 2008).\n\nFinally, in Martha Stewart, the defendant brought a post-trial motion alleging a host of deliberate omissions by a juror. 317 F. Supp. 2d at 438. Among the alleged deliberate omissions was that the juror had been fired from his job at Citibank for abusing drugs or improper expense accounting. Id. at 442. The district court denied a hearing with regard to this (and the other) allegations, as it was based on (a) statements of an individual who “appears to be reporting rumors,” and (b) an anonymous call to the defendant’s lawyer from an individual purporting to work for Citibank. Id. The Second Circuit affirmed that decision, noting that the defendant’s factual proffer as to this (and certain other) allegations was “insufficient.” Stewart, 433 F.3d at 305 & n.7. And although the Second Circuit stated in dicta that it might have held a hearing in the",
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  "entities": {
    "people": [
      "Guzman Loera",
      "Moon",
      "Bin Laden",
      "Martha Stewart"
    ],
    "organizations": [
      "Citibank",
      "DOJ"
    ],
    "locations": [
      "S.D.N.Y.",
      "E. Afr.",
      "U.S."
    ],
    "dates": [
      "03/11/22",
      "Feb. 7, 2005"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 643",
      "2022 WL 211199",
      "718 F.2d at 1234",
      "No. S7R 98 Cr. 1023 (KTD)",
      "2005 WL 287404",
      "552 F.3d 93",
      "317 F. Supp. 2d",
      "433 F.3d at 305",
      "DOJ-OGR-00009839"
    ]
  },
  "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 likely a page from a larger filing."
}