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

5532 Case 1:20-cr-00330-AJN Document 342 Filed 10/13/21 Page 8 of 17 downfall of other prominent New Yorkers due to sex scandals: former Governors David Paterson and Andrew Spitzer, former New York Attorney General Eric Schneiderman, former U.S. Congressman Andrew Wiener, not to mention the many New York-bas

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

t rare occurrences. Consider the 6 EFTA00011102 --- PAGE BREAK --- downfall of other prominent New Yorkers due to sex scandals: former Governors David Paterson and Andrew Spitzer, former New York Attorney General Eric Schneiderman, former U.S. Congressman Andrew Wiener, not to mention the many New York-bas

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

K --- Case 1:20-cr-00330-AJN Document 342 Filed 10/13/21 Page 8 of 17 downfall of other prominent New Yorkers due to sex scandals: former Governors David Paterson and Andrew Spitzer, former New York Attorney General Eric Schneiderman, former U.S. Congressman Andrew Wiener, not to mention the many New York-bas