mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00009137.json

{
  "document_metadata": {
    "page_number": "18",
    "document_number": "615",
    "date": "02/24/22",
    "document_type": "court document",
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  "full_text": "Case 1:20-cr-00330-PAE Document 615 Filed 02/24/22 Page 18 of 49\n\ninaccurately. But, as noted, that is not the end of the inquiry. And based on the currently available information, there is substantial reason to believe that any inaccuracy was an honest mistake, not a deliberate falsehood.\n\nJuror 50's only statements on the subject to date undermine the defendant's claim that he lied. Juror 50 has publicly stated that he \"flew through\" the questionnaire and did not recall being asked about his own history of sexual abuse. (Gov't Ex. C at 3). He repeatedly stated that he believed he had answered all the questions honestly. (Gov't Ex. A at 4; Gov't Ex. B at 8; Gov't Ex. C at 3). Indeed, when asked by an interviewer about whether he had disclosed his history of sexual abuse on the questionnaire, he confidently replied: \"No, they don't ask your sexual abuse history.\" (Def. Ex. 3 at :21). When the interviewer said that Question 48 asks about sexual abuse history, Juror 50 responded, in a puzzled tone, \"I don't remember.\" (Id. at :35). He continued, \"I would have definitely marked 'yes' but I honestly don't remember that question.\" (Id. at :54).\n\nThe defendant makes much of the fact that Juror 50 apparently began blushing, but that reaction is perfectly consistent with someone realizing they had just made a serious though honest mistake.\n\nIndeed, Juror 50 remembered a question about a family member or relative being sexually abused. (Id. at 1:09). And Question 48 asks: \"Have you or a friend or family member ever been the victim of sexual harassment, sexual abuse, or sexual assault?\" This question was nearly the last in a lengthy questionnaire composed of 51 questions, many with multiple sub-questions. Thus, a juror who was indeed flying through the questionnaire may have, by the 48th question (not including sub-questions), failed to notice that this question also asked about personal experiences.\n\nThough careful lawyers may have difficulty crediting that explanation, jurors can and do make mistakes. See, e.g., McDonough, 464 U.S. at 555 (\"[J]urors are not necessarily experts in English usage. Called as they are from all walks of life, many may be uncertain as to the meaning of terms\n\n16\nDOJ-OGR-00009137",
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  "entities": {
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    "dates": [
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      "Document 615",
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  "additional_notes": "The document appears to be a court filing related to a criminal case. The text discusses the responses of Juror 50 to a questionnaire and the implications of their answers. The document is well-formatted and free of significant damage or redactions."
}