Epstein Secrets

her Women: Behind Ghislaine Maxwell (Lisa Tait) • The Jeffrey Epstein Case: What We Do and Don't Know About Jeffrey Epstein and Ghislaine Maxwell (Stephen Wright) Much of the pretrial reporting, publications, and broadcasts refer to Epstein's 2008 case in Florida and the public outrage over his charges, plea

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

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

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

her Women: Behind Ghislaine Maxwell (Lisa Tait) • The Jeffrey Epstein Case: What We Do and Don't Know About Jeffrey Epstein and Ghislaine Maxwell (Stephen Wright) Much of the pretrial reporting, publications, and broadcasts refer to Epstein's 2008 case in Florida and the public outrage over his charges, plea

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

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

ther Women: Behind Ghislaine Maxwell (Lisa Tait) • The Jeffrey Epstein Case: What We Do and Don't Know About Je •ey Epstein and Ghislaine Maxwell (Stephen Wright) Much of the pretrial reporting, publications, and broadcasts refer to Epstein's 2008 case in Florida and the public outrage over his charges, plea