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694 KB
Extraction Summary
7
People
3
Organizations
0
Locations
1
Events
3
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
694 KB
Summary
This legal document presents an argument on behalf of Ms. Maxwell, asserting that Juror No. 50 engaged in misconduct by providing false answers under oath during jury selection (voir dire). The filing refutes the government's counterarguments, claiming the juror's dishonesty about being a victim of sexual abuse and his use of Twitter demonstrates implied bias and a deliberate pattern of falsehoods that should have resulted in his exclusion from the jury.
People (7)
| Name | Role | Context |
|---|---|---|
| Stewart |
Cited in a legal precedent (Stewart, 433 F.3d at 304).
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| Greer |
Cited in a legal precedent (Greer, 285 F.3d at 171 and 173).
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| Shaoul |
Cited in a legal precedent (United States v. Shaoul, 41 F.3d 811, 816).
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| McDonough |
Cited in a legal precedent regarding challenges for cause.
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| Daugerdas |
Cited as a legal precedent similar to the current case.
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| Juror No. 50 | Juror |
The subject of the legal argument, accused of misconduct, telling falsehoods, and being biased.
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| Ms. Maxwell | Defendant |
The individual on whose behalf the argument is being made, challenging the impartiality of Juror No. 50.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States | government agency |
Party in a cited case, United States v. Shaoul.
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| Court | government agency |
The judicial body hearing the case, which Juror No. 50 is accused of misleading.
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| company |
Social media platform that Juror No. 50 falsely denied using.
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Timeline (1 events)
The voir dire (jury selection) process during which Juror No. 50 allegedly gave false answers under oath.
Relationships (3)
Ms. Maxwell's legal team is arguing that Juror No. 50's misconduct and bias prevented a fair trial.
The document refutes the government's arguments regarding Juror No. 50's conduct.
The document alleges that Juror No. 50 told falsehoods to the Court during voir dire.
Key Quotes (2)
"the district court must determine if it would have granted the hypothetical challenge’ if it had known the true facts."Source
— Stewart (cited case)
(Quoted to establish the legal standard for evaluating a juror challenge after the fact.)
DOJ-OGR-00009891.jpg
Quote #1
"The deliberateness of the particular lies evidence[] partiality."Source
— Greer (cited case)
(Quoted to support the argument that Juror No. 50's false statements are evidence of his bias.)
DOJ-OGR-00009891.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,035 characters)
Case 1:20-cr-00330-PAE Document 644 Filed 03/11/22 Page 22 of 32
“This means that ‘the district court must determine if it would have granted the hypothetical challenge’ if it had known the true facts.” Id. (quoting Stewart, 433 F.3d at 304) (citing Greer, 285 F.3d at 171; United States v. Shaoul, 41 F.3d 811, 816 (2d Cir. 1994) (noting that under the second prong of McDonough, a defendant must have a basis for arguing that the district court is required to sustain his challenge for cause)). As in Daugerdas, and under any reading of McDonough, Juror No. 50’s misconduct demonstrates that he was incapable of being an impartial juror and the Court would have struck him for cause. See id.
The government’s contrary arguments do not withstand scrutiny. Foremost, the government mischaracterizes Ms. Maxwell’s argument and then attempts to shoot down the strawman. Ms. Maxwell does not argue that every person who has been a victim of sexual assault or sexual abuse was subject to a “mandatory” challenge for cause based on implied bias. Ms. Maxwell’s argument is simply that Juror No. 50 was impliedly biased—an argument more than supported by the record, Juror No. 50’s pattern and practice of telling falsehoods to the Court, and the statements of Juror No. 50 himself.
Likewise, the government misunderstands Ms. Maxwell’s argument about Juror No. 50’s false claims regarding his social media accounts. (Put aside for the moment the government’s implausible contention that on this score as well, Juror No. 50 didn’t mislead the Court, and surely didn’t do so deliberately.) Ms. Maxwell does not contend that Juror No. 50 would have been excluded for cause if he had admitted to being a Twitter user. The point is that Juror No. 50’s false denial of being a Twitter user is part of his pattern and practice of giving false answers under oath during voir dire, in a (successful) attempt to serve as a juror. “The deliberateness of the particular lies evidence[] partiality.” Greer, 285 F.3d at 173.
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DOJ-OGR-00009891
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