mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00009828.json

{
  "document_metadata": {
    "page_number": "30 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 30 of 49 serve as jurors in such cases, the defendant would have cited case law that actually supports that proposition. Finally, the defendant also argues that bias should be implied because she alleges that Juror 50 has repeatedly lied. (Def. Mem. at 35-36 (citing Daugerdas, 867 F. Supp. 2d at 472)). As discussed in greater detail above, the record does not support this, and, as a result, this is a far cry from the extreme circumstances in Daugerdas, where Judge Pauley concluded after a hearing that the juror \"created a totally fictitious persona in her drive to get on the jury\" and was \"a pathological liar who does not know the difference between truth and lie.\" Id. at 473, 475. The record also does not support the defendant's attempt to compare Juror 50 to Juror 55, who was dismissed for cause As noted above, there is no evidence that Juror 50 lied about his social media accounts. Moreover, the defendant's analogy misunderstands the nature of the current inquiry, in which the Court must consider the hypothetical question whether, if the juror had truthfully answered the relevant question, the Court would have struck him for cause. See Stewart, 433 F.3d at 304. But here, in a post-verdict posture, if the Court were to find that Juror 50 intentionally lied about using social media accounts, the question would be whether the Court would have struck him if he had truthfully answered that question. There is nothing in the record about Juror 50's use of social media accounts that would have supported a challenge for cause at voir dire. In sum, the defendant has failed to establish implied bias. 28 DOJ-OGR-00009828",
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    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 643 Filed 03/11/22 Page 30 of 49",
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    {
      "type": "printed",
      "content": "serve as jurors in such cases, the defendant would have cited case law that actually supports that proposition. Finally, the defendant also argues that bias should be implied because she alleges that Juror 50 has repeatedly lied. (Def. Mem. at 35-36 (citing Daugerdas, 867 F. Supp. 2d at 472)). As discussed in greater detail above, the record does not support this, and, as a result, this is a far cry from the extreme circumstances in Daugerdas, where Judge Pauley concluded after a hearing that the juror \"created a totally fictitious persona in her drive to get on the jury\" and was \"a pathological liar who does not know the difference between truth and lie.\" Id. at 473, 475. The record also does not support the defendant's attempt to compare Juror 50 to Juror 55, who was dismissed for cause",
      "position": "top"
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    {
      "type": "printed",
      "content": "As noted above, there is no evidence that Juror 50 lied about his social media accounts. Moreover, the defendant's analogy misunderstands the nature of the current inquiry, in which the Court must consider the hypothetical question whether, if the juror had truthfully answered the relevant question, the Court would have struck him for cause. See Stewart, 433 F.3d at 304. But here, in a post-verdict posture, if the Court were to find that Juror 50 intentionally lied about using social media accounts, the question would be whether the Court would have struck him if he had truthfully answered that question. There is nothing in the record about Juror 50's use of social media accounts that would have supported a challenge for cause at voir dire.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In sum, the defendant has failed to establish implied bias.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "28",
      "position": "footer"
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    {
      "type": "printed",
      "content": "DOJ-OGR-00009828",
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  "entities": {
    "people": [
      "Judge Pauley"
    ],
    "organizations": [
      "Court"
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    "locations": [],
    "dates": [
      "03/11/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "643",
      "DOJ-OGR-00009828"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with some redacted sections. The document is well-formatted and easy to read."
}