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

system of justice is deprived of its fullest potential when the lawyer is denied the right to examine veniremen in an adversary setting. Honorable Donald P. Lay (8th Cir.) "In a Fair Adversary System, the Lawyer Should Conduct the Voir Dire of the Jury." 15 EFTA00065541 Case 1:20-cr-00330-AJN Document 34

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

system of justice is deprived of its fullest potential when the lawyer is denied the right to examine veniremen in an adversary setting. Honorable Donald P. Lay (8th Cir.) "In a Fair Adversary System, the Lawyer Should Conduct the Voir Dire of the Jury." 15 EFTA00011111 --- PAGE BREAK --- Considering th

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

system of justice is deprived of its fullest potential when the lawyer is denied the right to examine veniremen in an adversary setting. Honorable Donald P. Lay (8th Cir.) "In a Fair Adversary System, the Lawyer Should Conduct the Voir Dire of the Jury." 15 EFTA00011130 --- PAGE BREAK --- Case 1:20-cr-0