Epstein Secrets

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

w: Ghislaine Maxwell (Peacock) Podcasts: • Chasing Ghislaine: The Untold Story of the Woman in Epstein's Shadow (Vicky Ward) • Hunting Ghislaine (John Sweeney) • The Ghislaine Maxwell Spiral (Audible) Books: • Ghislaine Maxwell (Steve H. Dwight) • Relentless Pursuit: My Fight for the Victims of Jeffrey

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

w: Ghislaine Maxwell (Peacock) Podcasts: • Chasing Ghislaine: The Untold Story of the Woman in Epstein's Shadow (Vicky Ward) • Hunting Ghislaine (John Sweeney) • The Ghislaine Maxwell Spiral (Audible) Books: • Ghislaine Maxwell (Steve H. Dwight) • Relentless Pursuit: My Fight for the Victims of Jeffrey

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

w: Ghislaine Maxwell (Peacock) Podcasts: • Chasing Ghislaine: The Untold Story of the Woman in Epstein's Shadow (Vicky Ward) • Hunting Ghislaine (John Sweeney) • The Ghislaine Maxwell Spiral (Audible) Books: • Ghislaine Maxwell (Steve H. Dwight) • Relentless Pursuit: My Fight for the Victims of Jeffrey