DOJ-OGR-00020903.json 6.9 KB

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  10. "full_text": "Case 22-1426, Document 58 02/28/2023, 3475901, Page77 of 221\nA-277\n28\nM38TMAX1 approached the questionnaire process, whether he took the Court's instructions seriously. We would just propose asking parallel questions about the questions we were asked in person, in particular because the juror was asked during voir dire similar questions about bias for or against the government, impartiality. And so to clarify the record, whether he took answering those questions in person seriously and answered truthfully.\nMS. STERNHEIM: Could we have a moment?\nTHE COURT: (Pause)\nMR. EVERDELL: Your Honor, I think there was several areas of follow-up here that are warranted.\nFirst, the juror made some reference to his healing process. I couldn't quite understand what he said at the time, something about how he views himself as a victim or not as a victim. I think you need to understand his healing process and what he has gone through, because that affects his ability to be an impartial juror in a case involving sexual trauma. Is this something that he is still thinking? How he deals with the healing process and how he thinks about himself as a victim affects how he views the victim witnesses in this case, and I think there ought to be more questions about that.\nTHE COURT: What's the proposed question?\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\n\n1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25\n\n27\nM38TMAX1 matter of the case would distract you in such a way that would distract you from your duty as a juror?\nA. No, your Honor.\nQ. Would you be thinking about your own experience in a way that would prevent you from being fair or impartial?\nA. No, your Honor.\nQ. At the time I asked you questions on November 16, and in light of your experience with sexual abuse, did you believe that issues of reporting sexual abuse might be discussed at trial or might interfere with your ability to be fair or impartial as a juror in the case?\nA. No, your Honor.\nQ. At the time I asked you questions on November 16, and if you had answered accurately and based on your experience with sexual abuse, did you have any doubt as to your ability to be fair to both sides?\nA. No, your Honor, no doubt.\nTHE COURT: All right. I will meet with counsel at sidebar.\n(At sidebar)\nTHE COURT: I will give you an opportunity to propose follow-up questions in light of his responses to questions of counsel.\nMS. MQRN: Yeah, your Honor, Just one proposal. I believe the Court asked Juror 50 about the way in which he\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\n\n1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25\nDOJ-OGR-00020903",
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  24. "content": "28\nM38TMAX1 approached the questionnaire process, whether he took the Court's instructions seriously. We would just propose asking parallel questions about the questions we were asked in person, in particular because the juror was asked during voir dire similar questions about bias for or against the government, impartiality. And so to clarify the record, whether he took answering those questions in person seriously and answered truthfully.\nMS. STERNHEIM: Could we have a moment?\nTHE COURT: (Pause)\nMR. EVERDELL: Your Honor, I think there was several areas of follow-up here that are warranted.\nFirst, the juror made some reference to his healing process. I couldn't quite understand what he said at the time, something about how he views himself as a victim or not as a victim. I think you need to understand his healing process and what he has gone through, because that affects his ability to be an impartial juror in a case involving sexual trauma. Is this something that he is still thinking? How he deals with the healing process and how he thinks about himself as a victim affects how he views the victim witnesses in this case, and I think there ought to be more questions about that.\nTHE COURT: What's the proposed question?",
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  39. "content": "27\nM38TMAX1 matter of the case would distract you in such a way that would distract you from your duty as a juror?\nA. No, your Honor.\nQ. Would you be thinking about your own experience in a way that would prevent you from being fair or impartial?\nA. No, your Honor.\nQ. At the time I asked you questions on November 16, and in light of your experience with sexual abuse, did you believe that issues of reporting sexual abuse might be discussed at trial or might interfere with your ability to be fair or impartial as a juror in the case?\nA. No, your Honor.\nQ. At the time I asked you questions on November 16, and if you had answered accurately and based on your experience with sexual abuse, did you have any doubt as to your ability to be fair to both sides?\nA. No, your Honor, no doubt.\nTHE COURT: All right. I will meet with counsel at sidebar.\n(At sidebar)\nTHE COURT: I will give you an opportunity to propose follow-up questions in light of his responses to questions of counsel.\nMS. MQRN: Yeah, your Honor, Just one proposal. I believe the Court asked Juror 50 about the way in which he",
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  60. "MS. STERNHEIM",
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