5
Shared Docs
5
Same-Page
5 / 7
Mentions
tton issues. See, e.g., Skilling v. United States, 130 S. Ct. 2896, 2919 (2010) (approving district court's use of questionnaire in trial of former Enron executive, Jeffrey Skilling); United States v. Robert Sylvester Kelly, 19 Cr. 286 (AMD) (EDNY) ("R. Kelly case"); United States v. Elizabeth Holmes
Page: EFTA00011099 →s, 511 F.3d 289, 301 (2d Cir. 2007) (quoting United States v. Haynes, 398 F.2d 980, 984 (2d Cir. 1968) and United States v. Torres, 128 F.3d 38, 45 (2d Cir. 1997)). All types of bias can properly form the basis to excuse a juror for cause. See id. Thus, the jury selection process should screen for each
Page: EFTA00011099 →98 --- PAGE BREAK --- ARGUMENT I. THE APPLICABLE LAW A prospective juror may be excused for cause based on many forms of bias or partiality. As the Second Circuit has explained, juror partiality can be actual, implied, or inferred: Actual bias is "bias in fact," generally evidenced by "express proof," such as
Page: EFTA00011099 →tton issues. See, e.g., Skilling v. United States, 130 S. Ct. 2896, 2919 (2010) (approving district court's use of questionnaire in trial of former Enron executive, Jeffrey Skilling); United States v. Robert Sylvester Kelly, 19 Cr. 286 (AMD) (EDNY) ("R. Kelly case"); United States v. Elizabeth Holmes
Page: EFTA00011118 →mandatory a presumption of bias." United States v. Quinones, 511 F.3d 289, 301 (2d Cir. 2007) (quoting United States v. Haynes, 398 F.2d 980, 984 (2d Cir. 1968) and United States v. Torres, 128 F.3d 38, 45 (2d Cir. 1997)). All types of bias can properly form the basis to excuse a juror for cause. See i
Page: EFTA00011118 →d 10/13/21 Page 4 of 17 ARGUMENT I. THE APPLICABLE LAW A prospective juror may be excused for cause based on many forms of bias or partiality. As the Second Circuit has explained, juror partiality can be actual, implied, or inferred: Actual bias is "bias in fact," generally evidenced by "express proof," such as
Page: EFTA00011118 →off was released on bail. He surrendered. Dryer called the colossal fraud by Judge Rakoff -- he surrendered and went to jail. Mr. Skilling from the Enron fame went to jail for 24 years. I recently had a case with Judge Furman where the government was arguing for detention that were associated with
T REPORTERS, P.C. EFTA00079801 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 reach the decision some day the Second Circuit may have to address about whether or not a wealthy person should be denied release because the private guard condition somehow is more like detent
tton issues. See, e.g., Skilling v. United States, 130 S. Ct. 2896, 2919 (2010) (approving district court's use of questionnaire in trial of former Enron executive, Jeffrey Skilling); United States v. Robert Sylvester Kelly, 19 Cr. 286 (AMD) (EDNY) ("R. Kelly case"); United States v. Elizabeth Holmes
d 10/13/21 Page 4 of 17 ARGUMENT I. THE APPLICABLE LAW A prospective juror may be excused for cause based on many forms of bias or partiality. As the Second Circuit has explained, juror partiality can be actual, implied, or inferred: Actual bias is "bias in fact," generally evidenced by "express proof," such as
off was released on bail. He surrendered. Dryer called the colossal fraud by Judge Rakoff -- he surrendered and went to jail. Mr. Skilling from the Enron fame went to jail for 24 years. I recently had a case with Judge Furman where the government was arguing for detention that were associated with
T REPORTERS, P.C. EFTA00095443 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 reach the decision some day the Second Circuit may have to address about whether or not a wealthy person should be denied release because the private guard condition somehow is more like detent
Entities connected to both Enron and Second Circuit

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Julie K. Brown
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Michael Cohen
PERSON
Supreme Court
ORGANIZATION
Donald Trump
PERSON
George W. Bush
PERSONJeffrey Pagliuca
PERSON
David Boies
PERSONMartin Weinberg
PERSON
Alan Dershowitz
PERSON
New York
LOCATION
Michael Jackson
PERSON
Stephen Hawking
PERSON