{
  "document_metadata": {
    "page_number": "83",
    "document_number": "59",
    "date": "02/28/2023",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 22-1426, Document 59, 02/28/2023, 3475902, Page83 of 113\n\nconcerned memories of events that occurred so long ago and that those memories of Maxwell's peripheral involvement in the abuse were motivated and distorted by external events. This issue was so central to the trial that the defendant called an expert to testify about memories.\n\nAssuming Juror 50 recounted a version of his abuse similar to what he described at the hearing and in media interviews, there is no question that he would have been excused on consent, stricken for cause or by an available peremptory challenge.12 In the event that Juror 50 answered truthfully, Juror 50 would have been questioned at length by the court, in camera. Honest answers to those questions would certainly have resulted in a valid challenge for cause.\n\nE. The District Court Abused its Discretion in the Manner in Which it Conducted the Post-Trial Hearing\n\nThe court abused its discretion in precluding cross-examination of Juror 50 by the defense and in limiting the scope of the questions.\n\n12 The potential jurors who admitted to being victims of sexual assault and were not stricken for cause, reported conduct such as groping, harassment at work or on the subway, and inappropriate touching in social settings - conduct that was drastically different than the abuse suffered by Juror 50 - drastically different from the abuse suffered by Juror 50 and the victims herein.\n\n68\nDOJ-OGR-00021130",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 22-1426, Document 59, 02/28/2023, 3475902, Page83 of 113",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "concerned memories of events that occurred so long ago and that those memories of Maxwell's peripheral involvement in the abuse were motivated and distorted by external events. This issue was so central to the trial that the defendant called an expert to testify about memories.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Assuming Juror 50 recounted a version of his abuse similar to what he described at the hearing and in media interviews, there is no question that he would have been excused on consent, stricken for cause or by an available peremptory challenge.12 In the event that Juror 50 answered truthfully, Juror 50 would have been questioned at length by the court, in camera. Honest answers to those questions would certainly have resulted in a valid challenge for cause.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "E. The District Court Abused its Discretion in the Manner in Which it Conducted the Post-Trial Hearing",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The court abused its discretion in precluding cross-examination of Juror 50 by the defense and in limiting the scope of the questions.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "12 The potential jurors who admitted to being victims of sexual assault and were not stricken for cause, reported conduct such as groping, harassment at work or on the subway, and inappropriate touching in social settings - conduct that was drastically different than the abuse suffered by Juror 50 - drastically different from the abuse suffered by Juror 50 and the victims herein.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "68",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00021130",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Juror 50",
      "Maxwell"
    ],
    "organizations": [],
    "locations": [
      "subway"
    ],
    "dates": [
      "02/28/2023"
    ],
    "reference_numbers": [
      "Case 22-1426",
      "Document 59",
      "3475902",
      "DOJ-OGR-00021130"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Maxwell. The text discusses the potential bias of Juror 50 and the court's handling of the post-trial hearing. The document is well-formatted and free of significant damage or redactions."
}