mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00021128.json

{
  "document_metadata": {
    "page_number": "81",
    "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, Page81 of 113\n\nD. Under the McDonough Test, Juror 50's Actual, Implied and Inferred Bias was established.\n\n1. The McDonough Test: The First Prong\n\n\"Intentionally false\" answers are not a prerequisite to satisfying the first prong of the McDonough test. Although the Court held that \"a party must first demonstrate that a juror failed to honestly answer a material question on voir dire,\" its focus on whether the juror was \"honest,\" did not mean that an inadvertent mistake or inaccurate answer, not given deliberately, would not satisfy the test. McDonough, 464 U.S. at 556. Quite the opposite, a verdict can be undermined, and a new trial ordered, \"regardless of whether a juror's answer is honest or dishonest.\" Id. at 557-59. Thus, \"false\" means inaccurate or materially misleading, not necessarily deliberately false or untruthful. United States v. Langford, 990 F. 2d 65, 68 (2d Cir. 1993). Here, as Juror No. 50's answers were plainly untrue, the first prong under McDonough was satisfied.\n\n2. The McDonough Test: The Second Prong\n\nPursuant to McDonough, once an untrue voir dire response has been discovered, the next question is would truthful answers have provided a valid basis for a challenge for cause? United States v. Stewart, 433 F.3d 273, 303 (2006). \"[T]he test is not whether the true facts would compel the Court to remove a juror for cause, but rather whether a truthful response 'would have provided a valid basis for cause, but rather whether a truthful response 'would have provided a valid basis'\n\n66\nDOJ-OGR-00021128",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 22-1426, Document 59, 02/28/2023, 3475902, Page81 of 113",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "D. Under the McDonough Test, Juror 50's Actual, Implied and Inferred Bias was established.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "1. The McDonough Test: The First Prong\n\n\"Intentionally false\" answers are not a prerequisite to satisfying the first prong of the McDonough test. Although the Court held that \"a party must first demonstrate that a juror failed to honestly answer a material question on voir dire,\" its focus on whether the juror was \"honest,\" did not mean that an inadvertent mistake or inaccurate answer, not given deliberately, would not satisfy the test. McDonough, 464 U.S. at 556. Quite the opposite, a verdict can be undermined, and a new trial ordered, \"regardless of whether a juror's answer is honest or dishonest.\" Id. at 557-59. Thus, \"false\" means inaccurate or materially misleading, not necessarily deliberately false or untruthful. United States v. Langford, 990 F. 2d 65, 68 (2d Cir. 1993). Here, as Juror No. 50's answers were plainly untrue, the first prong under McDonough was satisfied.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "2. The McDonough Test: The Second Prong\n\nPursuant to McDonough, once an untrue voir dire response has been discovered, the next question is would truthful answers have provided a valid basis for a challenge for cause? United States v. Stewart, 433 F.3d 273, 303 (2006). \"[T]he test is not whether the true facts would compel the Court to remove a juror for cause, but rather whether a truthful response 'would have provided a valid basis for cause, but rather whether a truthful response 'would have provided a valid basis'",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "66",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00021128",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "Court",
      "United States"
    ],
    "locations": [],
    "dates": [
      "02/28/2023",
      "2006",
      "1993"
    ],
    "reference_numbers": [
      "22-1426",
      "59",
      "3475902",
      "81",
      "113",
      "464 U.S. 556",
      "557-59",
      "990 F. 2d 65",
      "68",
      "2d Cir.",
      "433 F.3d 273",
      "303",
      "DOJ-OGR-00021128"
    ]
  },
  "additional_notes": "The document appears to be a court filing discussing the McDonough Test in relation to Juror 50. The text is printed and there are no visible stamps or handwritten notes. The document is well-formatted and legible."
}