mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00021133.json

{
  "document_metadata": {
    "page_number": "86",
    "document_number": "59",
    "date": "02/28/2023",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 22-1426, Document 59, 02/28/2023, 3475902, Page86 of 113\n\nparties were aware of such statements is due to Juror 50's own conduct. In such a situation, Juror 50 does not get to use 606(b) as a shield.\n\nRule 606(b)'s exception for extraneous prejudicial information is applicable here. First, had this information been disclosed, Juror 50 would have been disqualified or excluded from being a member of the jury. Second, his statements demonstrate that he used information, concealed during voir dire, to operate as an unsworn expert on the subject of traumatic memory for which he was not qualified.13 And, third, questioning Juror 50 about his statements to media would have provided the defense with an opportunity to establish through probing questions the credibility of Juror 50's conclusory protestations that he could be fair and establish a valid basis for a cause challenge. Thus, testimony on this topic was admissible as an exception to 606(b).\n\nF. The District Court Erred in Finding that (1) Juror 50 was Not Biased and (2) Juror 50 Would Not Have Been Stricken Even if He Had Answered the Questions Accurately\n\nHere, the District Court abused its discretion in unfairly limiting the hearing and in making clearly erroneous factual findings, namely, that Juror 50's hearing\n\n13 Dr. Elizabeth Loftus testified that people “don't just record events and play it back later like a recording device would work, like a video machine, but rather, we are actually constructing memories when we retrieve memories.” (Tr. at 2427). However, Juror No. 50 stated that the memories of the abuse he suffered can be “replayed like a video.” Lucia Osborn-Croweley, Ghislaine Maxwell Juror Breaks Silence To The Independent: This Verdict Is For All The Victims,” Independent (Jan. 4, 2022).\n\n71\n\nDOJ-OGR-00021133",
  "text_blocks": [
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      "type": "printed",
      "content": "Case 22-1426, Document 59, 02/28/2023, 3475902, Page86 of 113",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "parties were aware of such statements is due to Juror 50's own conduct. In such a situation, Juror 50 does not get to use 606(b) as a shield.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Rule 606(b)'s exception for extraneous prejudicial information is applicable here. First, had this information been disclosed, Juror 50 would have been disqualified or excluded from being a member of the jury. Second, his statements demonstrate that he used information, concealed during voir dire, to operate as an unsworn expert on the subject of traumatic memory for which he was not qualified.13 And, third, questioning Juror 50 about his statements to media would have provided the defense with an opportunity to establish through probing questions the credibility of Juror 50's conclusory protestations that he could be fair and establish a valid basis for a cause challenge. Thus, testimony on this topic was admissible as an exception to 606(b).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "F. The District Court Erred in Finding that (1) Juror 50 was Not Biased and (2) Juror 50 Would Not Have Been Stricken Even if He Had Answered the Questions Accurately",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Here, the District Court abused its discretion in unfairly limiting the hearing and in making clearly erroneous factual findings, namely, that Juror 50's hearing",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "13 Dr. Elizabeth Loftus testified that people “don't just record events and play it back later like a recording device would work, like a video machine, but rather, we are actually constructing memories when we retrieve memories.” (Tr. at 2427). However, Juror No. 50 stated that the memories of the abuse he suffered can be “replayed like a video.” Lucia Osborn-Croweley, Ghislaine Maxwell Juror Breaks Silence To The Independent: This Verdict Is For All The Victims,” Independent (Jan. 4, 2022).",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "71",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00021133",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Juror 50",
      "Dr. Elizabeth Loftus",
      "Lucia Osborn-Croweley",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "Independent"
    ],
    "locations": [],
    "dates": [
      "02/28/2023",
      "Jan. 4, 2022"
    ],
    "reference_numbers": [
      "Case 22-1426",
      "Document 59",
      "3475902",
      "DOJ-OGR-00021133"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document related to the Ghislaine Maxwell case. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and easy to read."
}