mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00009895.json

{
  "document_metadata": {
    "page_number": "26 of 32",
    "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 26 of 32\n\n2. The questioning should encompass any topic on which actual bias may be based.\n\nMoreover, the questioning should be significantly broader than proposed by the government. Although Ms. Maxwell need not prove Juror No. 50's intent, whether he acted deliberately is \"is among the 'factors to be considered' in the ultimate determination of bias. . .\" Greer, 285 F.3d at 173. An analysis of Juror No. 50's intent requires consideration of the totality of the circumstances. And if only because Juror No. 50 has a pattern and practice of giving false answers to the Court, Ms. Maxwell is not required to accept any post-hoc assertion by him that he did not act deliberately. Cf. United States v. James, 609 F.2d 36, 46 (2d Cir. 1979) (\"[W]hen attempting to show bias or interest, as opposed to bad reputation, the examiner is not bound to accept the witness' answer, but is free to call additional witnesses for impeachment.\")\n\nThe government disingenuously suggests that the Court \"need not inquire about the details of the victim's sexual abuse, just as the Court did not probe such details with respect to other jurors who answered Question 48 affirmatively.\" Resp. at 34 n.16. Apparently the government has forgotten that Question 48a itself (approved of by the government) asked for details of any affirmative answer to Question 48, and each of the other jurors who answered 48 in the affirmative provided those details in written form when they answered Question 48a.\n\nThere was thus no need for the Court to inquire the details during the live voir dire. For example, the government points to Juror 189 and notes the Court only followed up with the question whether a question concerning ability to be fair and impartial. Resp. at 36. Yet Juror 189's answer to 48a contained the details of her alleged abuse. The same with Juror 239:\n\n21\n\nDOJ-OGR-00009895",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 644 Filed 03/11/22 Page 26 of 32",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "2. The questioning should encompass any topic on which actual bias may be based.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Moreover, the questioning should be significantly broader than proposed by the government. Although Ms. Maxwell need not prove Juror No. 50's intent, whether he acted deliberately is \"is among the 'factors to be considered' in the ultimate determination of bias. . .\" Greer, 285 F.3d at 173. An analysis of Juror No. 50's intent requires consideration of the totality of the circumstances. And if only because Juror No. 50 has a pattern and practice of giving false answers to the Court, Ms. Maxwell is not required to accept any post-hoc assertion by him that he did not act deliberately. Cf. United States v. James, 609 F.2d 36, 46 (2d Cir. 1979) (\"[W]hen attempting to show bias or interest, as opposed to bad reputation, the examiner is not bound to accept the witness' answer, but is free to call additional witnesses for impeachment.\")",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government disingenuously suggests that the Court \"need not inquire about the details of the victim's sexual abuse, just as the Court did not probe such details with respect to other jurors who answered Question 48 affirmatively.\" Resp. at 34 n.16. Apparently the government has forgotten that Question 48a itself (approved of by the government) asked for details of any affirmative answer to Question 48, and each of the other jurors who answered 48 in the affirmative provided those details in written form when they answered Question 48a.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "There was thus no need for the Court to inquire the details during the live voir dire. For example, the government points to Juror 189 and notes the Court only followed up with the question whether a question concerning ability to be fair and impartial. Resp. at 36. Yet Juror 189's answer to 48a contained the details of her alleged abuse. The same with Juror 239:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "21",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00009895",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Greer",
      "James"
    ],
    "organizations": [
      "Court",
      "government"
    ],
    "locations": [],
    "dates": [
      "03/11/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 644",
      "285 F.3d",
      "609 F.2d 36",
      "Question 48",
      "Question 48a",
      "DOJ-OGR-00009895"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of United States v. Maxwell. The text discusses the scope of questioning for jurors and references specific jurors and court decisions. There are redactions in the text, indicated by black bars."
}