Page 7 - The People of the State of New York v. M. Robert Neulander - Brief for Amicus Curiae in Support of Defendant-Respondent

Court.

submission of
One of
consideration.
impartial jury.
1
impartial juror.
the necessity of

regularly handle some of

In addition, this brief
demonstrates that the ruling of
1 Pursuant to Rule 500.23(a)(4)(iii) of
This appeal is of

money to fund preparation or submission of
a new trial, regardless of
2
the brief.

this Court's Rules of

SUMMARYOFARGUMENT

the alleged strength of
The NYCDL offers the Court the collective experience of
and respectfully submits that its members' perspective will be of
where a juror's manifest dishonesty, misconduct, and violation of
The Fourth Department recognized the importance of
party's counsel contributed content to this brief, nor participated in the preparation of

instructions raises substantial questions about her ability to have served as an
N.Y. Civ. Rights Law Art. 2 § 12 is, in a criminal case, the right to trial by an
the evidence,
any other manner; (b) no party or party's counsel contributed money to fund preparation or
the most complex criminal cases in this state's courts,
particular concern to the NYCDL because the
approach taken by the trial court and endorsed by the two dissenting justices of
Practice, amicus states (a) that no
the trial court's
assistance to the
the Fourth Department is amply supported by case
the most fundamental rights protected by the Sixth Amendment and
law from other jurisdictions around the country, a perspective that the parties may
practitioners who
the
this right and
goes beyond the parties' focus on New York law, and
this brief; and (c) no person or entity, other than amicus or its counsel, contributed
the briefin
not have had the opportunity to present and that could otherwise escape the Court's