mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00009891.json

{
  "document_metadata": {
    "page_number": "22",
    "document_number": "644",
    "date": "03/11/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 644 Filed 03/11/22 Page 22 of 32\n\n\"This means that 'the district court must determine if it would have granted the hypothetical challenge' if it had known the true facts.\" Id. (quoting Stewart, 433 F.3d at 304) (citing Greer, 285 F.3d at 171; United States v. Shaoul, 41 F.3d 811, 816 (2d Cir. 1994) (noting that under the second prong of McDonough, a defendant must have a basis for arguing that the district court is required to sustain his challenge for cause)). As in Daugerdas, and under any reading of McDonough, Juror No. 50's misconduct demonstrates that he was incapable of being an impartial juror and the Court would have struck him for cause. See id.\n\nThe government's contrary arguments do not withstand scrutiny. Foremost, the government mischaracterizes Ms. Maxwell's argument and then attempts to shoot down the strawman. Ms. Maxwell does not argue that every person who has been a victim of sexual assault or sexual abuse was subject to a \"mandatory\" challenge for cause based on implied bias. Ms. Maxwell's argument is simply that Juror No. 50 was impliedly biased—an argument more than supported by the record, Juror No. 50's pattern and practice of telling falsehoods to the Court, and the statements of Juror No. 50 himself.\n\nLikewise, the government misunderstands Ms. Maxwell's argument about Juror No. 50's false claims regarding his social media accounts. (Put aside for the moment the government's implausible contention that on this score as well, Juror No. 50 didn't mislead the Court, and surely didn't do so deliberately.) Ms. Maxwell does not contend that Juror No. 50 would have been excluded for cause if he had admitted to being a Twitter user. The point is that Juror No. 50's false denial of being a Twitter user is part of his pattern and practice of giving false answers under oath during voir dire, in a (successful) attempt to serve as a juror. \"The deliberateness of the particular lies evidence[] partiality.\" Greer, 285 F.3d at 173.\n\n17\nDOJ-OGR-00009891",
  "text_blocks": [
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 644 Filed 03/11/22 Page 22 of 32",
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      "type": "printed",
      "content": "\"This means that 'the district court must determine if it would have granted the hypothetical challenge' if it had known the true facts.\" Id. (quoting Stewart, 433 F.3d at 304) (citing Greer, 285 F.3d at 171; United States v. Shaoul, 41 F.3d 811, 816 (2d Cir. 1994) (noting that under the second prong of McDonough, a defendant must have a basis for arguing that the district court is required to sustain his challenge for cause)). As in Daugerdas, and under any reading of McDonough, Juror No. 50's misconduct demonstrates that he was incapable of being an impartial juror and the Court would have struck him for cause. See id.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "The government's contrary arguments do not withstand scrutiny. Foremost, the government mischaracterizes Ms. Maxwell's argument and then attempts to shoot down the strawman. Ms. Maxwell does not argue that every person who has been a victim of sexual assault or sexual abuse was subject to a \"mandatory\" challenge for cause based on implied bias. Ms. Maxwell's argument is simply that Juror No. 50 was impliedly biased—an argument more than supported by the record, Juror No. 50's pattern and practice of telling falsehoods to the Court, and the statements of Juror No. 50 himself.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Likewise, the government misunderstands Ms. Maxwell's argument about Juror No. 50's false claims regarding his social media accounts. (Put aside for the moment the government's implausible contention that on this score as well, Juror No. 50 didn't mislead the Court, and surely didn't do so deliberately.) Ms. Maxwell does not contend that Juror No. 50 would have been excluded for cause if he had admitted to being a Twitter user. The point is that Juror No. 50's false denial of being a Twitter user is part of his pattern and practice of giving false answers under oath during voir dire, in a (successful) attempt to serve as a juror. \"The deliberateness of the particular lies evidence[] partiality.\" Greer, 285 F.3d at 173.",
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    {
      "type": "printed",
      "content": "17",
      "position": "footer"
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    {
      "type": "printed",
      "content": "DOJ-OGR-00009891",
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  ],
  "entities": {
    "people": [
      "Stewart",
      "Greer",
      "Shaoul",
      "McDonough",
      "Daugerdas",
      "Ms. Maxwell",
      "Juror No. 50"
    ],
    "organizations": [
      "Court",
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "03/11/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 644",
      "DOJ-OGR-00009891"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text discusses the government's arguments and Ms. Maxwell's counterarguments regarding Juror No. 50's misconduct and potential bias. The document includes citations to various court cases and statutes."
}