mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00010313.json

{
  "document_metadata": {
    "page_number": "7",
    "document_number": "649",
    "date": "03/15/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 649 Filed 03/15/22 Page 7 of 12\nLAW OFFICES OF BOBBI C. STERNHEIM\n\nabout how memory can be corrupted and rendered him incapable of objectively evaluating a\ncentral aspect of Ms. Maxwell's defense. (Motion at 32-33).\n\nThe Court should not credit Juror 50's repeated assurances that he would not, and did not,\nlet his past experience of sexual abuse affect his ability to fairly and impartially evaluate the\nevidence. Those answers were self-serving and are of no value to the Court's analysis of\npotential bias. Indeed, the Second Circuit had recognized that in determining whether implied or\ninferred bias exists, \"the juror's statements as to his or her ability to be impartial become\nirrelevant.\" Torres, 128 F.3d at 47. Instead, bias must be determined from the surrounding facts\nand circumstances—especially in cases where the juror's experience closely tracks the trial\nevidence—because \"the bias of a juror will rarely be admitted by the juror himself, 'partly\nbecause the juror may have an interest in concealing his own bias and partly because the juror\nmay be unaware of it.'\" Id. (quoting McDonough, 464 U.S. at 558). Here, the record establishes\nthat Juror 50 was biased and would have been struck for cause had he truthfully disclosed his\nhistory of sexual abuse.\n\nB. Juror 50's Answers to the Court's Questions Were Not Credible and Further\nRevealed His Bias\n\nJuror 50's responses to the Court's questions at the Hearing were rife with contradictions\nand inconsistencies. His explanation for his false statements on the jury questionnaire—that he\n\"flew through\" the questions and did not see that multiple questions called for him to disclose his\nsexual abuse—lacked all credibility. And his assertion that he did not think anyone would find\nout about his sexual abuse after giving three interviews to the international press, including a\nvideo interview, about his service as a juror on the most widely covered case in decades was\nutterly implausible. Juror 50's false statements and his explanation for those false statements, a\n7\nDOJ-OGR-00010313",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 649 Filed 03/15/22 Page 7 of 12",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "about how memory can be corrupted and rendered him incapable of objectively evaluating a\ncentral aspect of Ms. Maxwell's defense. (Motion at 32-33).\n\nThe Court should not credit Juror 50's repeated assurances that he would not, and did not,\nlet his past experience of sexual abuse affect his ability to fairly and impartially evaluate the\nevidence. Those answers were self-serving and are of no value to the Court's analysis of\npotential bias. Indeed, the Second Circuit had recognized that in determining whether implied or\ninferred bias exists, \"the juror's statements as to his or her ability to be impartial become\nirrelevant.\" Torres, 128 F.3d at 47. Instead, bias must be determined from the surrounding facts\nand circumstances—especially in cases where the juror's experience closely tracks the trial\nevidence—because \"the bias of a juror will rarely be admitted by the juror himself, 'partly\nbecause the juror may have an interest in concealing his own bias and partly because the juror\nmay be unaware of it.'\" Id. (quoting McDonough, 464 U.S. at 558). Here, the record establishes\nthat Juror 50 was biased and would have been struck for cause had he truthfully disclosed his\nhistory of sexual abuse.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "B. Juror 50's Answers to the Court's Questions Were Not Credible and Further\nRevealed His Bias",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Juror 50's responses to the Court's questions at the Hearing were rife with contradictions\nand inconsistencies. His explanation for his false statements on the jury questionnaire—that he\n\"flew through\" the questions and did not see that multiple questions called for him to disclose his\nsexual abuse—lacked all credibility. And his assertion that he did not think anyone would find\nout about his sexual abuse after giving three interviews to the international press, including a\nvideo interview, about his service as a juror on the most widely covered case in decades was\nutterly implausible. Juror 50's false statements and his explanation for those false statements, a",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "7",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010313",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Juror 50",
      "Bobbi C. Sternheim"
    ],
    "organizations": [
      "Second Circuit",
      "LAW OFFICES OF BOBBI C. STERNHEIM",
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "03/15/22"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 649",
      "DOJ-OGR-00010313"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, with a focus on the bias of Juror 50. The text is well-formatted and printed, with no visible handwriting or stamps."
}