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

5531 Case 1:20-cr-00330-AJN Document 342 Filed 10/13/21 Page 7 of 17 • Ghislaine Maxwell: The Rise and Fall of Manhattan's Most Famous Socialite (Nigel Cawthome) • The Spider: Insider the Criminal Web of Affrey Epstein and Ghislaine Maxwell (Barry Levin) • Jeffrey Epstein's Other Women: Behind Ghislaine

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

sion of Justice (Julie K. Brown) 5 EFTA00011101 --- PAGE BREAK --- • Ghislaine Maxwell: The Rise and Fall of Manhattan's Most Famous Socialite (Nigel Cawthome) • The Spider: Insider the Criminal Web of Jeey Epstein and Ghislaine Maxwell (Barry Levin) • Jeffrey Epstein's Other Women: Behind Ghislaine Ma

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

--- Case 1:20-cr-00330-AJN Document 342 Filed 10/13/21 Page 7 of 17 ■ Ghislaine Maxwell: The Rise and Fall of Manhattan's Most Famous Socialite (Nigel Cawthome) • The Spider: Insider the Criminal Web ofJeey Epstein and Ghislaine Maxwell (Barry Levin) • Jeffrey Epstein's Other Women: Behind Ghislaine Max