mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00009882.json

{
  "document_metadata": {
    "page_number": "13",
    "document_number": "644",
    "date": "03/11/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 644 Filed 03/11/22 Page 13 of 32\n\nThe government's invocation of Tanner and Ianniello is strikingly disingenuous. Both cases involved alleged conduct during trial and, crucially, during deliberations. The interest in \"shielding jury deliberations from public scrutiny\" is what motivated the Supreme Court's decision in Tanner, 483 U.S. at 119, and the Second Circuit's cautionary note in Ianniello, 866 F.2d at 543.\n\nIn this case, by contrast, there is at least one juror who falsely answered voir dire questions to gain a seat on the jury, conduct that occurred outside the jury room. The reluctance of courts to second-guess jury deliberations by inquiring into how the jury reached its decision simply has no relevance here, and neither do Tanner or Ianniello.\n\nIn fact, the government's reliance on Ianniello is doubly wrong, because the Second Circuit there set aside any reluctance it might have had to question the conduct of deliberations by ordering the defendant's requested evidentiary hearing. As the Court explained, \"a post-trial jury hearing must be held when a party comes forward with 'clear, strong, substantial and incontrovertible evidence . . . that a specific, non-speculative impropriety has occurred.'\" Ianniello, 866 F.2d at 543 (quoting United States v. Moon, 718 F.2d 1210, 1234 (2d Cir. 1983)).4\n\nHere, of course, the government concedes Ms. Maxwell's entitlement to an evidentiary hearing.\n\nThe government cannot with a straight face claim that Ms. Maxwell's motion risks exposing Juror No. 50 to harassment and intimidation. Let's be clear. The only reason Ms. Maxwell knows of Juror No. 50's false answers during voir dire is that Juror No. 50 has sought out the limelight. He has sat for several interviews with journalists, he has allowed himself to be videotaped, he has Tweeted and publicized himself on social media, and he has even participated\n\n4 To be clear, this standard does not apply to Ms. Maxwell's claim; it applies when a new trial motion alleges misconduct during deliberations. Ianniello, 866 F.3d at 543; Moon, 718 F.3d at 1234.\n\n8\nDOJ-OGR-00009882",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 644 Filed 03/11/22 Page 13 of 32",
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    {
      "type": "printed",
      "content": "The government's invocation of Tanner and Ianniello is strikingly disingenuous. Both cases involved alleged conduct during trial and, crucially, during deliberations. The interest in \"shielding jury deliberations from public scrutiny\" is what motivated the Supreme Court's decision in Tanner, 483 U.S. at 119, and the Second Circuit's cautionary note in Ianniello, 866 F.2d at 543.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "In this case, by contrast, there is at least one juror who falsely answered voir dire questions to gain a seat on the jury, conduct that occurred outside the jury room. The reluctance of courts to second-guess jury deliberations by inquiring into how the jury reached its decision simply has no relevance here, and neither do Tanner or Ianniello.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In fact, the government's reliance on Ianniello is doubly wrong, because the Second Circuit there set aside any reluctance it might have had to question the conduct of deliberations by ordering the defendant's requested evidentiary hearing. As the Court explained, \"a post-trial jury hearing must be held when a party comes forward with 'clear, strong, substantial and incontrovertible evidence . . . that a specific, non-speculative impropriety has occurred.'\" Ianniello, 866 F.2d at 543 (quoting United States v. Moon, 718 F.2d 1210, 1234 (2d Cir. 1983)).4",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Here, of course, the government concedes Ms. Maxwell's entitlement to an evidentiary hearing.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government cannot with a straight face claim that Ms. Maxwell's motion risks exposing Juror No. 50 to harassment and intimidation. Let's be clear. The only reason Ms. Maxwell knows of Juror No. 50's false answers during voir dire is that Juror No. 50 has sought out the limelight. He has sat for several interviews with journalists, he has allowed himself to be videotaped, he has Tweeted and publicized himself on social media, and he has even participated",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "4 To be clear, this standard does not apply to Ms. Maxwell's claim; it applies when a new trial motion alleges misconduct during deliberations. Ianniello, 866 F.3d at 543; Moon, 718 F.3d at 1234.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "8",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00009882",
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  ],
  "entities": {
    "people": [
      "Maxwell",
      "Tanner",
      "Ianniello",
      "Moon"
    ],
    "organizations": [
      "Supreme Court",
      "Second Circuit",
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "03/11/22"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 644",
      "DOJ-OGR-00009882"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 13 of 32."
}