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

t possible bias and prejudice of which the juror himself may be unaware until certain facts are revealed. Ledee, 549 F.2d at 993 (citing Frates and Greer, Jury Voir Dire: The Lawyer's Perspective, 2 A.B.A. Litigation No. 2 (1976)). Indeed, the Fifth Circuit later amplified this concept, stating that

lse answer is just as 23 EFTA00155930 invidious as an intentionally false answer. United States v. Langford, 990 F.2d 65, 68 (2d Cir. 1993)." As the Second Circuit held in Langford: We read [McDonough] multi-part test as governing not only inadvertent nondisclosures but also nondisclosures or misstatements tha

27 passim United States v. Eubanks, 591 F.2d 513 (9th Cir. 1979) 30 United States v. French, 904 F.3d 111 (1st Cir. 2018) 47 United States v. Greer, 285 F.3d 158 (2d Cir. 2002) 36 United States v. Haynes, 398 F.2d 980 (2d Cir. 1968) 29, 38 United States v. Langford, 990 F.2d 65(2d Cir. 1993)

ember of.the Massachusetts Bar-since April 24, 1972. 2. Movant is also admitted to practice before the United States Supreme Court, First Circuit, Second Circuit, Third Circuit; Fourth Circuit, Fifth Circuit, Sixth Circuit, Ninth Circuit, and Eleventh Circuit. 3. Movant designates RONALD G. NE1W1RT14, ESQ.,

of 8 Chicago, IL 60661 Lynn Maynard Gollin on behalf of Creditor Gibraltar PI Fait Bank and Trost 1441 Brickdl Ave 15 Fl Miami, FL 33131 Alan 0 Greer 201 S Biscayne Blvd 81000 Miami, FL 33401 Ridøgn Greer 250 Australian An S #1504 One Clcarlakc Cater West Palm Bead; FL 33401 Michael J Grimme

ember of.the Massachusetts Bar-since April 24, 1972. 2. Movant is also admitted to practice before the United States Supreme Court, First Circuit, Second Circuit, Third Circuit; Fourth Circuit, Fifth Circuit, Sixth Circuit, Ninth Circuit, and Eleventh Circuit. 3. Movant designates RONALD G. NE1W1RT14, ESQ.,

of 8 Chicago, IL 60661 Lynn Maynard Gollin on behalf of Creditor Gibraltar PI Fait Bank and Trost 1441 Brickdl Ave 15 Fl Miami, FL 33131 Alan 0 Greer 201 S Biscayne Blvd 81000 Miami, FL 33401 Ridøgn Greer 250 Australian An S #1504 One Clcarlakc Cater West Palm Bead; FL 33401 Michael J Grimme

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 possible bias and prejudice of which the juror himself may be unaware until certain facts are revealed. Ledee, 549 F.2d at 993 (citing Frates and Greer, Jury Voir Dire: The Lawyer's Perspective, 2 A.B.A. Litigation No. 2 (1976)). Indeed, the Fifth Circuit later amplified this concept, stating that

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

t possible bias and prejudice of which the juror himself may be unaware until certain facts are revealed. Ledee, 549 F.2d at 993 (citing Frates and Greer, Jury Voir Dire: The Lawyer's Perspective, 2 A.B.A. Litigation No. 2 (1976)). Indeed, the Fifth Circuit later amplified this concept, stating that