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

Relentless Pursuit: My Fight for the Victims of Jeffrey Epstein and Ghislaine Maxwell (Bradley Edwards) • Trash: Encounters with Ghislaine Maxwell (Christina Oxenberg) • Perversion of Justice (Julie K. Brown) 5 EFTA00065531 Case 1:20-cr-00330-AJN Document 342 Filed 10/13/21 Page 7 of 17 • Ghislaine Maxwell: T

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

Relentless Pursuit: My Fight for the Victims of Jeffrey Epstein and Ghislaine Maxwell (Bradley Edwards) • Trash: Encounters with Ghislaine Maxwell (Christina Oxenberg) • Perversion of Justice (Julie K. Brown) 5 EFTA00011101 --- PAGE BREAK --- • Ghislaine Maxwell: The Rise and Fall of Manhattan's Most Famous S

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

Relentless Pursuit: My Fight for the Victims of Jeffrey Epstein and Ghislaine Maxwell (Bradley Edwards) • Trash: Encounters with Ghislaine Maxwell (Christina Oxenberg) • Perversion of Justice (Julie K. Brown) 5 EFTA00011120 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 342 Filed 10/13/21 Page 7 of 17 ■