mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00021131.json

{
  "document_metadata": {
    "page_number": "84",
    "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, Page84 of 113\n\n1. The Court Erred in Precluding Defense Counsel From Questioning Juror 50\n\nOnce the court ordered a hearing, it was essential that Maxwell be afforded a meaningful opportunity to have her counsel participate in the hearing. Although judges normally enjoy “broad flexibility” in addressing claims of jury misconduct, cases involving “media publicity or other outside influences” constrain their leeway. United States v. Thai, 29 F. 3d 785, 803 (2d Cir. 1994). See, United States v. Daugerdas, Case No. 09-CR-581 (William H. Pauly) (procedure followed in identical situation acknowledged that defense counsel was in best position to conduct the examination of the juror).\n\nDefense counsel was not permitted to cross-examine Juror 50 and many of their proposed questions were rejected by the court. For example, the court refused inquiry into Juror 50’s statements about his “healing process;” his therapy and specifically whether he spoke with a therapist about the case during the trial; the details of his sexual abuse to assess how similar it was to the stories of the accusers; his social media use to the extent it contradicted his statements in voir dire; and his public statements both about traumatic memories and his participation as a juror. A277-281. The court should have permitted Maxwell’s attorneys to probe the impact that the sexual abuse had on the juror in other aspects of his life and assess whether his answers reflected an actual or implied bias as his voluntary post-verdict public comments surely did. The court’s hypothetical questions about\n\n69\n\nDOJ-OGR-00021131",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 22-1426, Document 59, 02/28/2023, 3475902, Page84 of 113",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1. The Court Erred in Precluding Defense Counsel From Questioning Juror 50",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Once the court ordered a hearing, it was essential that Maxwell be afforded a meaningful opportunity to have her counsel participate in the hearing. Although judges normally enjoy “broad flexibility” in addressing claims of jury misconduct, cases involving “media publicity or other outside influences” constrain their leeway. United States v. Thai, 29 F. 3d 785, 803 (2d Cir. 1994). See, United States v. Daugerdas, Case No. 09-CR-581 (William H. Pauly) (procedure followed in identical situation acknowledged that defense counsel was in best position to conduct the examination of the juror).",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Defense counsel was not permitted to cross-examine Juror 50 and many of their proposed questions were rejected by the court. For example, the court refused inquiry into Juror 50’s statements about his “healing process;” his therapy and specifically whether he spoke with a therapist about the case during the trial; the details of his sexual abuse to assess how similar it was to the stories of the accusers; his social media use to the extent it contradicted his statements in voir dire; and his public statements both about traumatic memories and his participation as a juror. A277-281. The court should have permitted Maxwell’s attorneys to probe the impact that the sexual abuse had on the juror in other aspects of his life and assess whether his answers reflected an actual or implied bias as his voluntary post-verdict public comments surely did. The court’s hypothetical questions about",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "69",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00021131",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Thai",
      "Daugerdas",
      "William H. Pauly",
      "Juror 50"
    ],
    "organizations": [
      "United States"
    ],
    "locations": [],
    "dates": [
      "02/28/2023"
    ],
    "reference_numbers": [
      "Case 22-1426",
      "Document 59",
      "3475902",
      "Page84 of 113",
      "29 F. 3d 785",
      "2d Cir. 1994",
      "Case No. 09-CR-581",
      "A277-281",
      "DOJ-OGR-00021131"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Maxwell. The text discusses the court's handling of a hearing regarding jury misconduct and the limitations placed on defense counsel's ability to question Juror 50. The document includes citations to legal precedents and references to specific pages in the record."
}