Epstein Secrets

r. 2006) (citing Lathrop v. Unidentified, Wrecked &Abandoned Vessel, 817 F. Supp. 953, 960 n.10 (M.D. Fla. 1993); Resort Timeshare Resales, Inc. v. Stuart, 764 F. Supp. 1495, 1500-01 (S.D. Fla. 1991). Ample authority and numerous instances exist in which courts have allowed parties who do not necessari

F.R.D. 583, 585 (S.D.N.Y. 1976) (denying motion to intervene, but allowing party to participate as amicus curiae in the case), ajf'd, 556 F.2d 554 (2d Cir. 1976); United States v. Mass. Mar. Acad., 76 F.R.D. 595, 598 (D. Mass. 1977) (same). Amicus status is particularly warranted where, as here, the put

30 Sunrise, FL 33323 Steven 1 Reisman on behalf of Creditor American Express Travel Related Services Company, ne 101 Park Ave New York, NY 10178 Stuart A Rosenfeklt on behalf of Defendant Stun RosenfeHt 4000 Hollywood Blvd 8265 S Hollywood, FL 33021 Michael Schlesinger on behalf of Creditor Frank

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.,

30 Sunrise, FL 33323 Steven 1 Reisman on behalf of Creditor American Express Travel Related Services Company, ne 101 Park Ave New York, NY 10178 Stuart A Rosenfeklt on behalf of Defendant Stun RosenfeHt 4000 Hollywood Blvd 8265 S Hollywood, FL 33021 Michael Schlesinger on behalf of Creditor Frank

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.,

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

void contaminating unbiased members of the venire when other members disclose prior knowledge of prejudicial information. Nebraska Press Ass 'n v. Stuart, 427 U.S. 539, 602 (1976). IL THE JURY POOL HAS BEEN AND WILL CONTINUE TO BE EXPOSED TO SUBSTANTIAL PRETRIAL PUBLICITY ABOUT GHISLAINE MAXWELL, JE

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

void contaminating unbiased members of the venire when other members disclose prior knowledge of prejudicial information. Nebraska Press Ass 'n v. Stuart, 427 U.S. 539, 602 (1976). II. THE JURY POOL HAS BEEN AND WILL CONTINUE TO BE EXPOSED TO SUBSTANTIAL PRETRIAL PUBLICITY ABOUT GHISLAINE MAXWELL, J