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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
Spider: Insider the Criminal Web of Affrey Epstein and Ghislaine Maxwell (Barry Levin) • Jeffrey Epstein's Other 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 reportin
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 →he Spider: Insider the Criminal Web of Jeey Epstein and Ghislaine Maxwell (Barry Levin) • Jeffrey Epstein's Other 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 reportin
Page: EFTA00011102 →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 →The Spider: Insider the Criminal Web ofJeey Epstein and Ghislaine Maxwell (Barry Levin) • Jeffrey Epstein's Other 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
Page: EFTA00011121 →Entities connected to both Second Circuit and Lisa Tait

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Julie K. Brown
PERSON
Bradley Edwards
PERSONJeffrey Pagliuca
PERSON
Donald Trump
PERSON
New York
LOCATION
Stephen Hawking
PERSON
Denver
LOCATIONCohen & Gresser LLP
ORGANIZATION
Harvey Weinstein
PERSONBobbi C. Sternheim
PERSON
Marc Rich
PERSON
Alexander Acosta
PERSON
Martha Stewart
PERSON
Vicky Ward
PERSON
Christian R. Everdell
PERSON
Torres
PERSON
the Fifth Circuit
ORGANIZATION