DOJ-OGR-00005343.json 6.9 KB

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  1. {
  2. "document_metadata": {
  3. "page_number": "21",
  4. "document_number": "367",
  5. "date": "10/22/21",
  6. "document_type": "Juror Questionnaire",
  7. "has_handwriting": false,
  8. "has_stamps": false
  9. },
  10. "full_text": "Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 21 of 35\nJuror ID: \n17. Do any of you have any opinion about the enforcement of the federal sex trafficking laws or the federal laws concerning sex crimes against minors that might prevent you from being fair and impartial in this case? Yes No If yes, please explain: \n18. Have you or a family member ever lobbied, petitioned, or worked in any other manner for or against any laws or regulations relating to sex trafficking or sex crimes against minors? Yes No If yes, please explain when and what you or your family member did: \nWhether reported or not, have you, any family member or anyone close to you, including a child/minor, ever been the victim of any form of sexual abuse? (This includes actual or attempted sexual assault or other unwanted sexual advance, including by a stranger, acquaintance, supervisor, teacher, or family member.) Yes No If yes, please explain: \nWhether reported or not, have you, or anyone close to you, including a child/minor, ever felt in danger of being sexually assaulted by another person, including a stranger, acquaintance, supervisor, teacher, or family member? Yes No If yes, please explain: \nHave you or anyone close to you ever participated in a class or discussion group, read books or articles listened to podcasts, or participated in blogs or chat rooms concerning sexual assault or sexual abuse? Yes No -21- DOJ-OGR-00005343\nCommented [A25]: GOVERNMENT OBJECTION: The Government objects to the next series of questions proposed by the defendant that are in green color font. The Government objects on the grounds that these questions are inappropriate, argumentative, confusing, and excessively detailed. The defendant's proposed questions are not streamlined in accordance with the Court's Order. The Government submits that its proposed questions ask the jurors what is necessary on the subject but is not as unduly burdensome as the defendant's proposal.\nCommented [A26R25]: DEFENDANT RESPONSE: Juror's personal experiences (directly or indirectly through family members and close friends) with sexual misconduct has significant potential to bias their opinions towards Ms. Maxwell based on the allegations and evidence in this case. The privacy of a questionnaire affords an opportunity to share these biases confidentially and candidly best allow the parties to identify who cannot be a fair juror in this case or allows the Court to decide whether individual questioning of that juror is appropriate, based on the sensitive nature of the content of the questions.",
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  14. "content": "Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 21 of 35",
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  17. {
  18. "type": "printed",
  19. "content": "Juror ID:",
  20. "position": "top"
  21. },
  22. {
  23. "type": "printed",
  24. "content": "17. Do any of you have any opinion about the enforcement of the federal sex trafficking laws or the federal laws concerning sex crimes against minors that might prevent you from being fair and impartial in this case? Yes No If yes, please explain:",
  25. "position": "middle"
  26. },
  27. {
  28. "type": "printed",
  29. "content": "18. Have you or a family member ever lobbied, petitioned, or worked in any other manner for or against any laws or regulations relating to sex trafficking or sex crimes against minors? Yes No If yes, please explain when and what you or your family member did:",
  30. "position": "middle"
  31. },
  32. {
  33. "type": "printed",
  34. "content": "Whether reported or not, have you, any family member or anyone close to you, including a child/minor, ever been the victim of any form of sexual abuse? (This includes actual or attempted sexual assault or other unwanted sexual advance, including by a stranger, acquaintance, supervisor, teacher, or family member.) Yes No If yes, please explain:",
  35. "position": "middle"
  36. },
  37. {
  38. "type": "printed",
  39. "content": "Whether reported or not, have you, or anyone close to you, including a child/minor, ever felt in danger of being sexually assaulted by another person, including a stranger, acquaintance, supervisor, teacher, or family member? Yes No If yes, please explain:",
  40. "position": "middle"
  41. },
  42. {
  43. "type": "printed",
  44. "content": "Have you or anyone close to you ever participated in a class or discussion group, read books or articles listened to podcasts, or participated in blogs or chat rooms concerning sexual assault or sexual abuse? Yes No",
  45. "position": "middle"
  46. },
  47. {
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  54. "content": "-21- DOJ-OGR-00005343",
  55. "position": "footer"
  56. },
  57. {
  58. "type": "handwritten",
  59. "content": "Commented [A25]: GOVERNMENT OBJECTION: The Government objects to the next series of questions proposed by the defendant that are in green color font. The Government objects on the grounds that these questions are inappropriate, argumentative, confusing, and excessively detailed. The defendant's proposed questions are not streamlined in accordance with the Court's Order. The Government submits that its proposed questions ask the jurors what is necessary on the subject but is not as unduly burdensome as the defendant's proposal.",
  60. "position": "margin"
  61. },
  62. {
  63. "type": "handwritten",
  64. "content": "Commented [A26R25]: DEFENDANT RESPONSE: Juror's personal experiences (directly or indirectly through family members and close friends) with sexual misconduct has significant potential to bias their opinions towards Ms. Maxwell based on the allegations and evidence in this case. The privacy of a questionnaire affords an opportunity to share these biases confidentially and candidly best allow the parties to identify who cannot be a fair juror in this case or allows the Court to decide whether individual questioning of that juror is appropriate, based on the sensitive nature of the content of the questions.",
  65. "position": "margin"
  66. }
  67. ],
  68. "entities": {
  69. "people": [
  70. "Ms. Maxwell"
  71. ],
  72. "organizations": [
  73. "Government",
  74. "Court"
  75. ],
  76. "locations": [],
  77. "dates": [
  78. "10/22/21"
  79. ],
  80. "reference_numbers": [
  81. "1:20-cr-00330-PAE",
  82. "367",
  83. "DOJ-OGR-00005343"
  84. ]
  85. },
  86. "additional_notes": "The document is a juror questionnaire for a court case involving sex trafficking and sex crimes against minors. The questionnaire includes questions about the juror's opinions on the enforcement of federal laws, their personal experiences with sexual abuse, and their participation in discussions or classes related to sexual assault. The document also includes comments from the government and the defendant regarding the proposed questions."
  87. }