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717 KB
Extraction Summary
5
People
3
Organizations
0
Locations
2
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
717 KB
Summary
This legal document, filed on behalf of Ms. Maxwell's defense by the Law Offices of Bobbi C. Sternheim, argues that Juror 50 was biased and should have been struck from the jury. The filing asserts that the juror's failure to disclose his history of sexual abuse, coupled with his incredible explanations for false statements on a questionnaire, demonstrates a bias that his own assurances of impartiality cannot overcome. The document cites legal precedents from the Second Circuit to support the claim that juror bias must be determined from circumstances, not the juror's self-serving statements.
People (5)
| Name | Role | Context |
|---|---|---|
| BOBBI C. STERNHEIM | Attorney |
Mentioned in the header under "LAW OFFICES OF BOBBI C. STERNHEIM".
|
| Ms. Maxwell | Defendant |
Mentioned in the context of her defense.
|
| Juror 50 | Juror |
The main subject of the document, whose credibility and potential bias are being discussed.
|
| Torres |
Cited in a legal case (Torres, 128 F.3d at 47) regarding juror impartiality.
|
|
| McDonough |
Cited in a legal case (McDonough, 464 U.S. at 558) regarding juror bias.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| LAW OFFICES OF BOBBI C. STERNHEIM | company |
Appears in the header of the document.
|
| The Court | government agency |
Referenced throughout the document as the body that should not credit Juror 50's assurances and whose questions Juror...
|
| Second Circuit | government agency |
Cited as a legal authority that has recognized principles regarding juror bias.
|
Relationships (1)
The document is from the Law Offices of Bobbi C. Sternheim and argues in favor of Ms. Maxwell's defense, indicating an attorney-client relationship.
Key Quotes (3)
"the juror’s statements as to his or her ability to be impartial become irrelevant."Source
— Second Circuit (via Torres case)
(Cited as a legal precedent from the Second Circuit in the case of Torres, 128 F.3d at 47, to argue against accepting a juror's self-assessment of impartiality.)
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Quote #1
"the bias of a juror will rarely be admitted by the juror himself, ‘partly because the juror may have an interest in concealing his own bias and partly because the juror may be unaware of it.’"Source
— McDonough case
(Quoted from the McDonough case to explain why bias must be determined from surrounding facts rather than a juror's own statements.)
DOJ-OGR-00010313.jpg
Quote #2
"flew through"Source
— Juror 50
(Juror 50's explanation for his false statements on the jury questionnaire, claiming he "flew through" the questions.)
DOJ-OGR-00010313.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,102 characters)
Case 1:20-cr-00330-PAE Document 649 Filed 03/15/22 Page 7 of 12
LAW OFFICES OF BOBBI C. STERNHEIM
LAW OFFICES OF BOBBI C. STERNHEIM
about how memory can be corrupted and rendered him incapable of objectively evaluating a
central aspect of Ms. Maxwell’s defense. (Motion at 32-33).
central aspect of Ms. Maxwell’s defense. (Motion at 32-33).
The Court should not credit Juror 50’s repeated assurances that he would not, and did not,
let his past experience of sexual abuse affect his ability to fairly and impartially evaluate the
evidence. Those answers were self-serving and are of no value to the Court’s analysis of
potential bias. Indeed, the Second Circuit had recognized that in determining whether implied or
inferred bias exists, “the juror’s statements as to his or her ability to be impartial become
irrelevant.” Torres, 128 F.3d at 47. Instead, bias must be determined from the surrounding facts
and circumstances—especially in cases where the juror’s experience closely tracks the trial
evidence—because “the bias of a juror will rarely be admitted by the juror himself, ‘partly
because the juror may have an interest in concealing his own bias and partly because the juror
may be unaware of it.’” Id. (quoting McDonough, 464 U.S. at 558). Here, the record establishes
that Juror 50 was biased and would have been struck for cause had he truthfully disclosed his
history of sexual abuse.
let his past experience of sexual abuse affect his ability to fairly and impartially evaluate the
evidence. Those answers were self-serving and are of no value to the Court’s analysis of
potential bias. Indeed, the Second Circuit had recognized that in determining whether implied or
inferred bias exists, “the juror’s statements as to his or her ability to be impartial become
irrelevant.” Torres, 128 F.3d at 47. Instead, bias must be determined from the surrounding facts
and circumstances—especially in cases where the juror’s experience closely tracks the trial
evidence—because “the bias of a juror will rarely be admitted by the juror himself, ‘partly
because the juror may have an interest in concealing his own bias and partly because the juror
may be unaware of it.’” Id. (quoting McDonough, 464 U.S. at 558). Here, the record establishes
that Juror 50 was biased and would have been struck for cause had he truthfully disclosed his
history of sexual abuse.
B. Juror 50’s Answers to the Court’s Questions Were Not Credible and Further
Revealed His Bias
Revealed His Bias
Juror 50’s responses to the Court’s questions at the Hearing were rife with contradictions
and inconsistencies. His explanation for his false statements on the jury questionnaire—that he
“flew through” the questions and did not see that multiple questions called for him to disclose his
sexual abuse—lacked all credibility. And his assertion that he did not think anyone would find
out about his sexual abuse after giving three interviews to the international press, including a
video interview, about his service as a juror on the most widely covered case in decades was
utterly implausible. Juror 50’s false statements and his explanation for those false statements, a
and inconsistencies. His explanation for his false statements on the jury questionnaire—that he
“flew through” the questions and did not see that multiple questions called for him to disclose his
sexual abuse—lacked all credibility. And his assertion that he did not think anyone would find
out about his sexual abuse after giving three interviews to the international press, including a
video interview, about his service as a juror on the most widely covered case in decades was
utterly implausible. Juror 50’s false statements and his explanation for those false statements, a
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