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

vision stations, radio, and streaming platforms, such as 1 EFTA00065527 Case 1:20-cr-00330-AJN Document 342 Filed 10/13/21 Page 3 of 17 Netflix, Peacock, and Amazon; in podcasts and YouTube recordings; in social media sites, such as Facebook, Instagram, Twitter; in online sites, chat rooms and blogs.

cast media, including regular and cable television stations, radio, and streaming platforms, such as 1 EFTA00011097 --- PAGE BREAK --- Netflix, Peacock, and Amazon; in podcasts and YouTube recordings; in social media sites, such as Facebook, Instagram, Twitter; in online sites, chat rooms and blogs.

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

radio, and streaming platforms, such as EFTA00011116 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 342 Filed 10/13/21 Page 3 of 17 Netflix, Peacock, and Amazon; in podcasts and YouTube recordings; in social media sites, such as Facebook, Instagram, Twitter; in online sites, chat rooms and blogs.

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