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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
mention the many New York-based television celebrities against whom serious allegations of sexual abuse have been alleged: Matt Lauer, Roger Ailes, Bill O'Reilly. The fact that a woman now stands trial for charges almost exclusively alleged against men heightens the interest and intrigue of this case. There
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 →mention the many New York-based television celebrities against whom serious allegations of sexual abuse have been alleged: Matt Lauer, Roger Ailes, Bill O'Reilly. The fact that a woman now stands trial for charges almost exclusively alleged against men heightens the interest and intrigue of this case. There
Page: EFTA00011103 →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 →mention the many New York-based television celebrities against whom serious allegations of sexual abuse have been alleged: Matt Lauer, Roger Ailes, Bill O'Reilly. The fact that a woman now stands trial for charges almost exclusively alleged against men heightens the interest and intrigue of this case. There
Page: EFTA00011122 →Entities connected to both Second Circuit and Bill O'Reilly

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONthe Southern District
LOCATION
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Michael Cohen
PERSONJeffrey Pagliuca
PERSON
Donald Trump
PERSON
David Boies
PERSON
New York
LOCATION
Michael Jackson
PERSON
George W. Bush
PERSON
Stephen Hawking
PERSON
Alan Dershowitz
PERSON
Denver
LOCATION
Harvey Weinstein
PERSON