mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00009152.json

{
  "document_metadata": {
    "page_number": "33",
    "document_number": "615",
    "date": "02/24/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 615 Filed 02/24/22 Page 33 of 49\n\n\"[t]he object of the proceeding is to permit the truth to be discovered with the least possible harm to other interests.\" United States v. Gagnon, 282 F. App'x 39, 40 (2d Cir. 2008) (quoting Moten, 582 F.2d at 666); see also Miller v. United States, 403 F.2d 77, 82 (2d Cir. 1969) (court should avoid \"dangers presented by inquiries that go beyond objective facts: inhibition of jury-room deliberations, harassment of jurors, and increased incidence of jury tampering.\") Indeed, \"the proper functioning of the jury system requires that the courts protect jurors from being harassed and beset by the defeated party in an effort to secure from them evidence of facts which might establish misconduct sufficient to set aside a verdict.\" Moten, 582 F.2d at 664 (quotation omitted). Thus, \"when and if it becomes apparent that the . . . reasonable grounds to suspect prejudicial jury impropriety do not exist, the inquiry should end.\" Sun Myung Moon, 718 F.2d at 1234.\n\nThe district court \"has the power and the duty to supervise and closely control such inquiries.\" United States v. Calbas, 821 F.2d 887, 896 (2d Cir. 1987). For example, the Court may choose to personally conduct the questioning of a juror in order to avoid intruding on the jury's deliberations. See, e.g., Calbas, 821 F.2d at 896. A district court may also determine to hold the hearing in camera. See Ianniello, 866 F.2d at 544; see also United States v. Shakur, 723 F. Supp. 925, 928 (S.D.N.Y. 1988), aff'd 888 F.2d 234 (2d Cir. 1989).\n\nB. Discussion\n\nFor the reasons set forth above, the Government believes that the exacting standard for a post-verdict hearing has been met only with respect to Juror 50 and the apparent inconsistency between his several public statements (including one on video) about being a victim of sexual abuse and his answer to Question 48 on the juror questionnaire. Thus, the Government consents to a hearing in order to determine (1) whether Juror 50 deliberately lied in response to Question",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 615 Filed 02/24/22 Page 33 of 49",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "\"[t]he object of the proceeding is to permit the truth to be discovered with the least possible harm to other interests.\" United States v. Gagnon, 282 F. App'x 39, 40 (2d Cir. 2008) (quoting Moten, 582 F.2d at 666); see also Miller v. United States, 403 F.2d 77, 82 (2d Cir. 1969) (court should avoid \"dangers presented by inquiries that go beyond objective facts: inhibition of jury-room deliberations, harassment of jurors, and increased incidence of jury tampering.\") Indeed, \"the proper functioning of the jury system requires that the courts protect jurors from being harassed and beset by the defeated party in an effort to secure from them evidence of facts which might establish misconduct sufficient to set aside a verdict.\" Moten, 582 F.2d at 664 (quotation omitted). Thus, \"when and if it becomes apparent that the . . . reasonable grounds to suspect prejudicial jury impropriety do not exist, the inquiry should end.\" Sun Myung Moon, 718 F.2d at 1234.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "The district court \"has the power and the duty to supervise and closely control such inquiries.\" United States v. Calbas, 821 F.2d 887, 896 (2d Cir. 1987). For example, the Court may choose to personally conduct the questioning of a juror in order to avoid intruding on the jury's deliberations. See, e.g., Calbas, 821 F.2d at 896. A district court may also determine to hold the hearing in camera. See Ianniello, 866 F.2d at 544; see also United States v. Shakur, 723 F. Supp. 925, 928 (S.D.N.Y. 1988), aff'd 888 F.2d 234 (2d Cir. 1989).",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "B. Discussion",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "For the reasons set forth above, the Government believes that the exacting standard for a post-verdict hearing has been met only with respect to Juror 50 and the apparent inconsistency between his several public statements (including one on video) about being a victim of sexual abuse and his answer to Question 48 on the juror questionnaire. Thus, the Government consents to a hearing in order to determine (1) whether Juror 50 deliberately lied in response to Question",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "31",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00009152",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Gagnon",
      "Moten",
      "Miller",
      "Sun Myung Moon",
      "Calbas",
      "Ianniello",
      "Shakur",
      "Juror 50"
    ],
    "organizations": [
      "United States",
      "Court",
      "Government",
      "Department of Justice"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "02/24/22",
      "2008",
      "1969",
      "1987",
      "1988",
      "1989"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 615",
      "DOJ-OGR-00009152"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 33 of 49."
}