mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00010296.json

{
  "document_metadata": {
    "page_number": "6",
    "document_number": "648",
    "date": "03/15/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 648 Filed 03/15/22 Page 6 of 16\n\nquestions, there was papers being ripped off the questionnaire packets, and there's a lot of talking going on, and it's super distracting.\" (Id. at 12:12-20, 14:11-12). He candidly told the Court that he wanted to finish the questionnaire, and that he never expected to actually serve on the jury, given the \"sheer volume of people there.\" (Id. at 12:2-3, 12:17, 13:18, 14:12-13; see also id. at 18:6-11 (explaining that \"growing up in school I never wanted to be last one finished. You want to finish your test and go hang out with your friends. So it's kind[] of that same policy . . . everyone else is finishing . . . I'm like: I'm never going to get chosen, let's get this done with.\")). He contrasted filling out the later questions of the questionnaire with the earlier questions where he \"was still . . . in focus and in the zone\" and \"had more focus than [he] did at the end and less distractions, so it was easier to follow along.\" (Id. at 19:14-20).2\n\nJuror 50 testified that he \"[a]bsolutely [did] not\" \"in any way intentionally provide an inaccurate answer\" to Question 48; that he \"[a]bsolutely [did] not\" answer no to Question 48 to \"make it more likely that [he] would be selected for the jury\"; and that he did \"[n]ot at all\" try to tailor his answers about his history of sexual abuse to \"make it more likely that [he] would be selected for the jury.\" (Id. at 15:23-16:8). And he was emphatic that \"this is never anything that [he] intended or did on purpose,\" and he \"certainly wouldn't have put [him]self in . . . this position.\" (Id. at 23:2-8).\n\n2 To be sure, Juror 50 should have realized that Question 48 was asking about his own experience and not just those of family and friends, given the purpose of the questionnaire. But as he testified, while he realizes in retrospect that this is information the parties would have wanted to know, at the time he \"honestly didn't think about it.\" (Mar. 8, 2022 Tr. at 21:17-22:3). Given Juror 50's testimony about his lack of focus at this point in the questionnaire, and the fact that jurors cannot be held to the standard of trained lawyers, this fact does not detract from his credibility. See McDonough, 464 U.S. at 555 (\"Called as they are from all walks of life, many [jurors] may be uncertain as to the meaning of terms.\"); Dyer v. Calderon, 151 F.3d 970, 973 (9th Cir. 1998) (\"[W]e must be tolerant, as jurors may forget incidents long buried in their minds, misunderstand a question or bend the truth a bit to avoid embarrassment.\").\n\n4\nDOI-OGR-00010296",
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      "content": "questions, there was papers being ripped off the questionnaire packets, and there's a lot of talking going on, and it's super distracting.\" (Id. at 12:12-20, 14:11-12). He candidly told the Court that he wanted to finish the questionnaire, and that he never expected to actually serve on the jury, given the \"sheer volume of people there.\" (Id. at 12:2-3, 12:17, 13:18, 14:12-13; see also id. at 18:6-11 (explaining that \"growing up in school I never wanted to be last one finished. You want to finish your test and go hang out with your friends. So it's kind[] of that same policy . . . everyone else is finishing . . . I'm like: I'm never going to get chosen, let's get this done with.\")). He contrasted filling out the later questions of the questionnaire with the earlier questions where he \"was still . . . in focus and in the zone\" and \"had more focus than [he] did at the end and less distractions, so it was easier to follow along.\" (Id. at 19:14-20).2",
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      "content": "Juror 50 testified that he \"[a]bsolutely [did] not\" \"in any way intentionally provide an inaccurate answer\" to Question 48; that he \"[a]bsolutely [did] not\" answer no to Question 48 to \"make it more likely that [he] would be selected for the jury\"; and that he did \"[n]ot at all\" try to tailor his answers about his history of sexual abuse to \"make it more likely that [he] would be selected for the jury.\" (Id. at 15:23-16:8). And he was emphatic that \"this is never anything that [he] intended or did on purpose,\" and he \"certainly wouldn't have put [him]self in . . . this position.\" (Id. at 23:2-8).",
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      "content": "2 To be sure, Juror 50 should have realized that Question 48 was asking about his own experience and not just those of family and friends, given the purpose of the questionnaire. But as he testified, while he realizes in retrospect that this is information the parties would have wanted to know, at the time he \"honestly didn't think about it.\" (Mar. 8, 2022 Tr. at 21:17-22:3). Given Juror 50's testimony about his lack of focus at this point in the questionnaire, and the fact that jurors cannot be held to the standard of trained lawyers, this fact does not detract from his credibility. See McDonough, 464 U.S. at 555 (\"Called as they are from all walks of life, many [jurors] may be uncertain as to the meaning of terms.\"); Dyer v. Calderon, 151 F.3d 970, 973 (9th Cir. 1998) (\"[W]e must be tolerant, as jurors may forget incidents long buried in their minds, misunderstand a question or bend the truth a bit to avoid embarrassment.\").",
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      "content": "DOI-OGR-00010296",
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    "dates": [
      "03/15/22",
      "Mar. 8, 2022"
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      "1:20-cr-00330-PAE",
      "648",
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