mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00010307.json

{
  "document_metadata": {
    "page_number": "1 of 12",
    "document_number": "649",
    "date": "03/15/22",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 649 Filed 03/15/22 Page 1 of 12 LAW OFFICES OF BOBBI C. STERNHEIM 212-243-1100 * Main 917-912-9698 * Cell 888-587-4737 * Fax 225 Broadway, Suite 715 New York, NY 10007 bcsternheim@mac.com March 15, 2022 Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Judge Nathan: We respectfully submit this letter following the hearing on March 8, 2022 (the “Hearing”) in further support of Ghislaine Maxwell’s Motion for a New Trial (“Motion”). The Court has now heard from Juror 50 in his own words. If there is one thing we learned from Juror 50 at the Hearing, it is this: he should never have been a member of this jury. Juror 50 conceded that he gave false responses to not one, but three critical questions on the juror questionnaire, all of which, had he answered them truthfully, would have revealed his prior sexual abuse. The abuse Juror 50 described at the Hearing, which he should have disclosed on the questionnaire and during voir dire, was remarkably similar to the abuse described by the government’s four key victim witnesses and would, by itself, have formed the basis for a challenge for cause. Moreover, his answers to the Court’s questions, which he gave after careful preparation by his attorney and under the protection of government-granted immunity, alternated between inconsistent, implausible, and contradictory, and at all times lacked credibility. Juror 50’s explanation that he “flew through” the questionnaire does not hold water, and his repeated after-the-fact assurances that the sexual abuse he suffered as a child did not affect his ability to be a fair and impartial juror were self-serving and simply not believable. Like anyone in his position, Juror 50 does not want to be responsible for the retrial of Ghislaine DOJ-OGR-00010307",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 649 Filed 03/15/22 Page 1 of 12",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "212-243-1100 * Main 917-912-9698 * Cell 888-587-4737 * Fax 225 Broadway, Suite 715 New York, NY 10007 bcsternheim@mac.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "March 15, 2022",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan: We respectfully submit this letter following the hearing on March 8, 2022 (the “Hearing”) in further support of Ghislaine Maxwell’s Motion for a New Trial (“Motion”).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Court has now heard from Juror 50 in his own words. If there is one thing we learned from Juror 50 at the Hearing, it is this: he should never have been a member of this jury. Juror 50 conceded that he gave false responses to not one, but three critical questions on the juror questionnaire, all of which, had he answered them truthfully, would have revealed his prior sexual abuse. The abuse Juror 50 described at the Hearing, which he should have disclosed on the questionnaire and during voir dire, was remarkably similar to the abuse described by the government’s four key victim witnesses and would, by itself, have formed the basis for a challenge for cause. Moreover, his answers to the Court’s questions, which he gave after careful preparation by his attorney and under the protection of government-granted immunity, alternated between inconsistent, implausible, and contradictory, and at all times lacked credibility. Juror 50’s explanation that he “flew through” the questionnaire does not hold water, and his repeated after-the-fact assurances that the sexual abuse he suffered as a child did not affect his ability to be a fair and impartial juror were self-serving and simply not believable. Like anyone in his position, Juror 50 does not want to be responsible for the retrial of Ghislaine",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010307",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Juror 50",
      "Bobbi C. Sternheim"
    ],
    "organizations": [
      "Law Offices of Bobbi C. Sternheim",
      "United States Courthouse"
    ],
    "locations": [
      "New York",
      "NY",
      "Broadway"
    ],
    "dates": [
      "March 15, 2022",
      "March 8, 2022",
      "03/15/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 649",
      "S2 20 Cr. 330 (AJN)",
      "DOJ-OGR-00010307"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the Law Offices of Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter discusses Juror 50's responses during a hearing and argues that he should not have been a member of the jury due to his false responses on the juror questionnaire and his prior sexual abuse. The document is well-formatted and printed, with no visible handwriting or stamps."
}