mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00009832.json

{
  "document_metadata": {
    "page_number": "34 of 49",
    "document_number": "643",
    "date": "03/11/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 643 Filed 03/11/22 Page 34 of 49\n48, and, if so, (2) whether the Court would have struck Juror 50 for cause if he had accurately responded to that question, i.e., whether he was actually biased.\nFor the reasons set forth below, the Government submits that: (1) the Court should conduct the questioning; (2) the questions for Juror 50 should be narrowly tailored; (3) there is no basis to call any other jurors as witnesses; and (4) the defendant's request for \"pre-hearing discovery\" should be denied.\n1. The Court Should Conduct the Questioning\nFirst, as noted, given the dangers of harassment and embarrassment presented by juror inquiries, the Court has the power and duty to closely control the proceedings. The Court can—and courts in this District frequently do—choose to personally question the jurors, often giving the parties an opportunity to propose to the Court questions for the Court to ask. See, e.g., Calbas, 821 F.2d at 896 (district court conducted examination of juror, and Second Circuit concluded that the district court “wisely refrained from allowing the inquiry to become an adversarial evidentiary hearing, so as to minimize intrusion on the jury's deliberations”); Loliscio v. Goord, 263 F.3d 178, 191 (2d Cir. 2001) (“[T]he scope of such a post-verdict inquiry, and the extent, if any, to which the parties may participate therein are matters left to the sound discretion of the trial court.”); Chase Manhattan Bank, N.A. v. T&N, No. 87 Civ. 4436 (JGK), 1997 WL 221203, at *8 (S.D.N.Y. Apr. 28, 1997) (“The Court examined Juror No. 5 under oath in the presence of counsel for both parties, after both parties were given the opportunity to submit proposed questions. To protect the juror from harassment or embarrassment, the Court personally conducted the questioning of the juror.”); United States v. Shakur, 723 F. Supp. 925, 928 (S.D.N.Y. 1988) (district court examined juror in camera, after permitting counsel to file suggested questions), aff'd 888 F.2d 234 (2d Cir. 1989); United States v. Greer, 998 F. Supp. 399, 404 (D. Vt. 1998) (“All of the jurors were\n32\nDOJ-OGR-00009832",
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      "content": "Case 1:20-cr-00330-PAE Document 643 Filed 03/11/22 Page 34 of 49",
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      "content": "48, and, if so, (2) whether the Court would have struck Juror 50 for cause if he had accurately responded to that question, i.e., whether he was actually biased.\nFor the reasons set forth below, the Government submits that: (1) the Court should conduct the questioning; (2) the questions for Juror 50 should be narrowly tailored; (3) there is no basis to call any other jurors as witnesses; and (4) the defendant's request for \"pre-hearing discovery\" should be denied.",
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    {
      "type": "printed",
      "content": "1. The Court Should Conduct the Questioning",
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    {
      "type": "printed",
      "content": "First, as noted, given the dangers of harassment and embarrassment presented by juror inquiries, the Court has the power and duty to closely control the proceedings. The Court can—and courts in this District frequently do—choose to personally question the jurors, often giving the parties an opportunity to propose to the Court questions for the Court to ask. See, e.g., Calbas, 821 F.2d at 896 (district court conducted examination of juror, and Second Circuit concluded that the district court “wisely refrained from allowing the inquiry to become an adversarial evidentiary hearing, so as to minimize intrusion on the jury's deliberations”); Loliscio v. Goord, 263 F.3d 178, 191 (2d Cir. 2001) (“[T]he scope of such a post-verdict inquiry, and the extent, if any, to which the parties may participate therein are matters left to the sound discretion of the trial court.”); Chase Manhattan Bank, N.A. v. T&N, No. 87 Civ. 4436 (JGK), 1997 WL 221203, at *8 (S.D.N.Y. Apr. 28, 1997) (“The Court examined Juror No. 5 under oath in the presence of counsel for both parties, after both parties were given the opportunity to submit proposed questions. To protect the juror from harassment or embarrassment, the Court personally conducted the questioning of the juror.”); United States v. Shakur, 723 F. Supp. 925, 928 (S.D.N.Y. 1988) (district court examined juror in camera, after permitting counsel to file suggested questions), aff'd 888 F.2d 234 (2d Cir. 1989); United States v. Greer, 998 F. Supp. 399, 404 (D. Vt. 1998) (“All of the jurors were",
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      "content": "32",
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      "content": "DOJ-OGR-00009832",
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  "entities": {
    "people": [],
    "organizations": [
      "Government",
      "Court",
      "Second Circuit",
      "Chase Manhattan Bank"
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    "locations": [
      "District",
      "S.D.N.Y.",
      "D. Vt."
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    "dates": [
      "03/11/22",
      "Apr. 28, 1997"
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    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 643",
      "87 Civ. 4436 (JGK)"
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  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
}