mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00005365.json

{
  "document_metadata": {
    "page_number": "8",
    "document_number": "367-1",
    "date": "10/22/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 367-1 Filed 10/22/21 Page 8 of 17 If you are selected as a juror in this matter, after you have heard all the evidence, you will deliberate. During deliberations, if you find you are of one view and all the rest of the jurors are of an opposite view, you remain convinced by reason and by logic that you are correct, will you have the strength of your convictions to adhere to your decision, notwithstanding the fact that all the other jurors disagree with you? If a friend or loved one was standing trial here, on the same charges, do you know of any reason why you would not be satisfied to have his or her case tried by someone in your frame of mind or with the attitudes and beliefs that you hold? Given the high-profile nature of this case and the sensitive nature of the charges, is there any reason why you would feel pressure - personally, professionally, ethically, politically, religiously - to return a verdict other than one based only on the evidence? [If Yes/Unsur, question privately.] Knowledge of the Trial Participants As noted in your questionnaire, the defendant, Ghislaine Maxwell, is represented by Christian Everdell, Laura Menninger, Jeffrey Pagliuca, and Bobbi Sternheim. Seeing them here today, do any of you know Mr. Everdell, Ms. Menninger, Mr. Pagliuca, or Ms. Sternheim? Has any juror had any dealings with them or individuals in their offices? They will be assisted by senior paralegal specialist Ann Lundberg. Similarly, as noted in your questionnaire, the prosecution, referred to here as the Government, is represented by this Court by the United States Attorney for the Southern District of New York, Damian Williams. The conduct of the trial will be in the immediate charge of Assistant United States Attorneys Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach. They will be assisted by FBI Special Agent Amanda Patton. Commented [A1(109)]GOVERNMENT OBJECTION: Ghislaine Maxwell is the defendant and should be referred to as such in the case in virtually every instance, and not as Ms. Maxwell. Commented [A1(109)]DEFENDANT RESPONSE: Ms. Maxwell is merely accused of the conduct in the charges and this questionnaire, a point that bears repeating. Commented [A1(11)]DEFENDANT RESPONSE: The defense objects that this language is pejorative and other language before this Court at issue. No other word has been used by the US attorneys or other representatives of the Court (including the ICE) at numerous prior proceedings before this Court by the United States. 7 DOJ-OGR-00005365",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 367-1 Filed 10/22/21 Page 8 of 17",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "If you are selected as a juror in this matter, after you have heard all the evidence, you will deliberate. During deliberations, if you find you are of one view and all the rest of the jurors are of an opposite view, you remain convinced by reason and by logic that you are correct, will you have the strength of your convictions to adhere to your decision, notwithstanding the fact that all the other jurors disagree with you? If a friend or loved one was standing trial here, on the same charges, do you know of any reason why you would not be satisfied to have his or her case tried by someone in your frame of mind or with the attitudes and beliefs that you hold? Given the high-profile nature of this case and the sensitive nature of the charges, is there any reason why you would feel pressure - personally, professionally, ethically, politically, religiously - to return a verdict other than one based only on the evidence? [If Yes/Unsur, question privately.]",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "Knowledge of the Trial Participants As noted in your questionnaire, the defendant, Ghislaine Maxwell, is represented by Christian Everdell, Laura Menninger, Jeffrey Pagliuca, and Bobbi Sternheim. Seeing them here today, do any of you know Mr. Everdell, Ms. Menninger, Mr. Pagliuca, or Ms. Sternheim? Has any juror had any dealings with them or individuals in their offices? They will be assisted by senior paralegal specialist Ann Lundberg. Similarly, as noted in your questionnaire, the prosecution, referred to here as the Government, is represented by this Court by the United States Attorney for the Southern District of New York, Damian Williams. The conduct of the trial will be in the immediate charge of Assistant United States Attorneys Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach. They will be assisted by FBI Special Agent Amanda Patton.",
      "position": "main"
    },
    {
      "type": "handwritten",
      "content": "Commented [A1(109)]GOVERNMENT OBJECTION: Ghislaine Maxwell is the defendant and should be referred to as such in the case in virtually every instance, and not as Ms. Maxwell. Commented [A1(109)]DEFENDANT RESPONSE: Ms. Maxwell is merely accused of the conduct in the charges and this questionnaire, a point that bears repeating. Commented [A1(11)]DEFENDANT RESPONSE: The defense objects that this language is pejorative and other language before this Court at issue. No other word has been used by the US attorneys or other representatives of the Court (including the ICE) at numerous prior proceedings before this Court by the United States.",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "7",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005365",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ghislaine Maxwell",
      "Christian Everdell",
      "Laura Menninger",
      "Jeffrey Pagliuca",
      "Bobbi Sternheim",
      "Ann Lundberg",
      "Damian Williams",
      "Maurene Comey",
      "Alison Moe",
      "Lara Pomerantz",
      "Andrew Rohrbach",
      "Amanda Patton"
    ],
    "organizations": [
      "United States Attorney for the Southern District of New York",
      "FBI"
    ],
    "locations": [
      "Southern District of New York"
    ],
    "dates": [
      "10/22/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "367-1",
      "DOJ-OGR-00005365"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the trial of Ghislaine Maxwell. The text includes questions for potential jurors and information about the trial participants. The document has been annotated with comments from both the government and the defendant."
}