Document 367

Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 2 of 35 Juror ID: DO NOT DO YOUR OWN RESEARCH ON THE CASE. Do not conduct any research into the case at any time before your jury service has been completed. (except in the presence of the Court), your fellow jurors, your family, your friends, or anyone else. Do not communicate about the case in any way, including telephone, e-mail, any social media app or website (such as Facebook) any communications app or website (such as Twitter). You must also avoid reading or hearing about the case (or anyone participating in the case) in newspapers, on the radio or television (or any other electronic means). That includes performing Internet searches, asking other people about the case, or reading news stories, books, or reports about the case, or watching films or television programs about the case. Do not read, watch, or listen to any information that could embarrass you or cause you to form an opinion about the case. If you believe that any of your answers on the confidential and not distributed beyond the blank pages at the end of the form. (Please identify the specific answer or answers on which you wish to request privacy and wish to counsel and judge and counsel to keep them confidential.) After the jury has been selected, all copies of your responses to the questionnaire will be returned to the Court. SUMMARY OF THE CASE The Court is selecting a jury for a trial commencing on Monday, November 29, 2021. Although it is never possible to predict the length of a trial, currently this trial is expected to last approximately [ ] weeks. This is a criminal case. The defendant, Ghislaine Maxwell, has been charged in an indictment with various criminal offenses. The indictment is evidence. It simply contains the charges - that the Government intends to prove to the jury at trial beyond a "reasonable doubt." The charges in the Indictment stem from allegations that from at least 1994 through 2004, the defendant conspired with and aided and abetted Jeffrey Epstein to entice minors to engage in criminal sexual activity and to transport minors in sex trafficking of a minor. The Indictment charges the defendant in 6 counts. Count One of the Indictment charges the defendant with conspiring with Jeffrey Epstein to entice minors to engage in criminal sexual activity for which a person can be charged with a criminal offense. Count Two charges the defendant with enticing a minor in a criminal sexual activity. Count Three charges the defendant with enticing minors in sexual activity for which a person can be charged with a criminal offense, and abetting the same. Count Four charges the defendant with conspiring with Epstein in transporting minors to engage in sexual activity, which is a criminal offense. Count Five charges the defendant with participating in a sex trafficking conspiracy. Count Six charges the defendant with sex trafficking of a minor, and aiding and abetting the same. Commented [A2]: The parties will submit a joint letter to the Court on October 12, 2021 providing an estimate of the trial length. DOJ-OGR-00005324 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 3 of 35 Juror ID: _____________________________________ Ms. Maxwell has pled not guilty to all charges. Ms. Maxwell is presumed innocent, and before she can be found guilty on any charge, the jury must find that the Government has proven each element of that crime beyond a reasonable doubt. (Please turn the page and read and complete the questionnaire.) -3- DOJ-OGR-00005325 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 5 of 35 Juror ID: Do (did) you supervise other people? Yes No Please briefly describe what your management and/or supervisory responsibilities have entailed: If you have held any other occupations in the past five years, please identify them here: What is the highest level of education you have completed? Less than high school High school graduate Some college/vocational training College graduate. If so, please indicate degree and/or field of study: Post-graduate degree. If so, please indicate degree and/or field of study: Please list all educational institutions you have attended, beginning with high school: Please complete the following questions regarding your present spouse or domestic partner/significant other. If you are divorced, widowed, or separated, please answer the following questions regarding your former spouse, partner or significant other's employment: What is his or her current employment status? Employed full-time Employed part-time Self-employed Homemaker Unemployed/laid-off Disabled Retired Full-time student (please state area of study) Other (please describe) What is his or her occupation (or what was it, if he or she is no longer employed)? By whom is (was) he or she employed? -5- DOJ-OGR-00005327 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 6 of 35 Juror ID: How long has (did) he or she work there? What are (were) his or her specific duties at the job? Does he or she supervise other people? Yes No Do you have any children, including step-children? Yes No If YES, please list the following for each: (Please include children you are currently raising or have ever raised even if they are not your biological children.) Gender Age Child Living with You Highest Level of Education Occupation/School Level (Do NOT list names of employers or schools) Yes No Yes No Yes No Yes No Yes No Yes No What are your hobbies, major interests, recreational pastimes and spare time activities and sports? What are your spouse/domestic partner/significant other's hobbies, major interests, recreational pastimes and spare time activities and sports? Please list any groups and/or organizations to which you belong (for example, religious groups, professional organizations, volunteer activities, victim's rights groups, etc.): If you have ever been a published or unpublished author, please describe the things you have written and when you wrote them: -6- DOJ-OGR-00005328 --- PAGE BREAK --- Page 7 of 35 Filed 10/22/21 Document 367 Case 1:20-cr-00330-PAE Commented [A67]: GOVERNMENT OBJECTION: The Government objects to this question on the grounds that it is vague, and will not provide a basis for a for-cause challenge. When in a group trying to make a decision, do you usually: Strongly express your views to get the outcome you believe is best Participate in the discussion and try to help build a consensus Listen and follow what you think the majority favors Other (please describe) Do you have any strong views regarding people who are wealthy? Yes No If Yes, please explain: Do you have any strong views regarding people who have luxurious lifestyles? Yes No If Yes, please explain: Commented [A87]: GOVERNMENT OBJECTION: The Government objects that these questions are vague and disputative, and not framed in a way that would provide a basis for a for-cause challenge. Commented [A97]: This sentence still refers to a visit letter to the Court October 12, 2021 providing an estimate of the trial length. If you are selected as a juror, you will be required to be present for the taking of testimony, which means you will go home every day after the trial lasts. There are no plans to sequester the jury, which means you All jury service involves some degree of hardship. Our court and justice system depends citizens doing their civic duty to serve as jurors which involves temporarily putting aside their regular business or professional service on a jury for jury service. The Court's inconvenience or the usual financial hardship a citizen owes for jury service is not sufficient to be excused from serious service on a jury for jury service. The Court's inconvenience or the usual financial hardship a citizen owes for jury service is not sufficient to be excused from serious financial hardship to be excused from serious service on a jury. You must show extraordinary personal or financial hardship to be excused from serious service on a jury. You must show extraordinary personal or financial hardship to be excused from serious service on a jury. Do any circumstances exist such that you would entail serious hardship or extreme inconvenience? Yes No 1. DOJ-OGR-00005329 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 8 of 35 Juror ID: If yes, please briefly describe the undue hardship or extreme inconvenience: Please note: In the event you are excused from service on this jury, you will not be excused from jury service in general. You will instead be required to report to the Court's Jury Clerk for placement on another panel for another case. 2. Do you have any personal commitments that would make it difficult for you to get to court by 9:30 a.m., every day of trial, or remain at the courthouse until [5:30 p.m.]? Yes No If yes, please explain why you would be unable to get to court by 9:30 a.m. or remain until [5:30 p.m.]: 3. Do you have any difficulty reading, speaking, or understanding English? Yes No 4. Do you have any medical, physical, or mental condition or illness that makes you unable to serve on a jury, including difficulty hearing, seeing, reading, or concentrating? Yes No If yes, please briefly describe the condition or illness. If you believe you could serve as a juror if such condition were accommodated in some way, please state the accommodation. 5. Are you taking any medication which would prevent you from giving full attention to all the evidence at this trial? Yes No If yes, please explain: -8- DOJ-OGR-00005330 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 9 of 35 Juror ID: 6. Do you have any pre-paid travel plans between November 29, 2021 and January 15, 2022? Yes No If yes, please describe your plans and the dates of travel (without indicating the name of where you work or the names of family members or friends, or other personal information that might identify who you are); No 7. Do you have any holiday plans for the period December 24th through January 3rd? Yes No Do you have any appointments during the next [] weeks that cannot be changed? Yes No If yes please explain: Have you received a vaccine for COVID-19? Yes No If Yes, when did you receive the vaccine? In light of the COVID-19 pandemic, do you have concerns about your ability to concentrate at trial, consider all the evidence, and make a conscientious decision in deliberation? Yes No If yes, would courtroom precautions (e.g. use of air filters, use of a larger courtroom) alleviate your concerns? Yes No Is there any reason relating to the COVID-19 pandemic that would make jury service an undue hardship for you or anyone in your household? Yes No If yes, please explain: Is there anything else going on in your life that would prevent you from giving this case your full attention for the duration of trial? Yes No If yes, please explain: Commented [A9]: GOVERNMENT OBJECTION. The Government objects to this question on the grounds that the Government objects to this question on the grounds that the defendant proposed this question. Commented [A12P]: The defendant proposed this question resulting to COVID-19. The Government takes no position. Commented [A12F]: The defendant proposed this question resulting to COVID-19. The Government takes no position. Commented [A11]: The parties will submit a joint letter to the Court on October 12, 2021 providing an estimate of the trial length. DOJ-OGR-00005331 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 10 of 35 Juror ID: _______________________________________ 8. Do you or does any member of your family or a close friend personally know or have past or present dealings with any of the following individuals? a. The defendant in this case, Ghislaine Maxwell, or her family members Yes No b. Jeffrey Epstein Yes No c. The U.S. Attorney for the Southern District of New York, Damian Williams, or anyone else who works for or used to work for the U.S. Attorney's Office for the Southern District of New York? Yes No d. Any of the Assistant United States Attorneys who are prosecuting this case: Maurene Comey Yes No Alison Moe Yes No Lara Pomerantz Yes No Andrew Rohrbach Yes No e. Any of the defense attorneys or law firms who are representing the defendant: Christian Everdell of Cohen & Gresser LLP Yes No Jeffrey Pagliuca of Haddon, Morgan and Foreman, P.C. Yes No Laura Menninger of Haddon, Morgan and Foreman, P.C. Yes No Bobbi Sternheim of Law Offices of Bobbi C. Sternheim Yes No f. The United States District Court Judge who is presiding over this case, Alison J. Nathan, or anyone who works on her staff? Yes No If you answered "yes" to any of the above sub-questions (8.a, 8.b, 8.c, 8.d, 8.e, or 8.f), please explain whom you know, how you know the individual(s), and whether your relationship with that person might make it difficult for you to be a fair and impartial juror in this case: ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ -10- DOJ-OGR-00005332 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 11 of 35 Juror ID: CHARGES AND INDIVIDUALS INVOLVED The indictment alleges that Ghislaine Maxwell conspired with Jeffrey Epstein and did entice minor females to travel to engage in illegal sex acts, transported a minor female to engage in criminal sexual activity, and engaged in sex trafficking of a minor. The indictment is not evidence; it is a formal way of charging a person with a crime in order to bring her to trial. Ms. Maxwell has pleaded not guilty. She is presumed innocent. Unless the government proves that she is guilty of these charges beyond a reasonable doubt, the jury must return a verdict of not guilty. Would the fact that Ms. Maxwell faces a number of charges lead you to believe that she must be guilty of something? Yes No If yes, please explain: Please indicate if you ever had any connection with any of the following? Palm Beach County (Florida) Police Department Yes No Federal Bureau of Investigations Yes No U.S. Attorney's Office -Southern District of Florida Yes No U.S. Attorney's Office- Southern District of New York Yes No U.S. Department of Justice Yes No If you indicated Yes, please explain your connection: EXPERIENCE WITH LEGAL SYSTEM Have you ever served as a juror at trial or in a grand jury? Yes No If yes, how many times? -11- DOJ-OGR-00005333 Commented [A13]: GOVERNMENT OBJECTION: The Government objects to the “Charges & Individuals Involved” section proposed by the defendant on the grounds that it is duplicative of the questions proposed by the Government. In particular, the first question is duplicative of questions above and is argumentative and inappropriate. Commented [A14R13]: DEFENDANT RESPONSE: The Government has not identified which questions they believe are duplicative. The first question, pertaining to the number of charges, does not appear to be duplicative in any Government-proposed question. The Second Circuit has specifically approved discussion pf the presumption of innocence in jury selection. See United States v. Velez-Vasquez, 116 F.3d 58, 61 (2d Cir. 1997) (upholding conviction where judge forgot to instruct on presumption of innocence in closing instructions where the concept had been discussed during voir dire). Commented [A15]: GOVERNMENT OBJECTION: The Government objects to any references to the Southern District of Florida at this trial. The U.S. Attorney’s Office for the Southern District of Florida is not prosecuting this case. As the Government will address in a motion in limine, references to the USAO-SDFL are not appropriate at this trial. Commented [A16]: GOVERNMENT OBJECTION: The Government does not believe the questions in the “Experience with Legal System” section should be included in the written questionnaire, because these questions will not reveal any bias or otherwise provide a basis for a for-cause challenge. Rather, the Government submits that such questions should be asked during the oral voir dire. Commented [A17R16]: DEFENDANT RESPONSE: The defense believes that asking these questions on the questionnaire will save substantial amount of time and will allow the Court (and potentially parties) to follow up at the time of voir dire. Access to the information ahead of the voir dire will allow the Court to prepare to ask individual questions as necessary, some of which may best be asked outside the presence of other jurors (for example a prospective juror who previously had a negative experience as a juror). --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 12 of 35 Juror ID: __________________________________ Did you serve as a juror in state or federal court? Yes No Were you ever the foreperson of the jury? Yes No If applicable, please briefly describe the case(s) in which you served as a juror using the following table: Criminal or Civil Type of case (e.g., fraud, personal injury, etc.) Did the jury reach a verdict? Yes No Yes No Yes No Yes No Yes No What stands out most to you about your experience as a juror? Please explain ____________________________________________________________________ Is there anything about that experience that would affect your ability to be a fair and impartial juror in this case? Yes No Have you, a family member, or someone close to you ever been involved in a civil or criminal proceeding as a plaintiff (the party suing), defendant (the party being sued), or potential witness? Yes No If Yes, please explain: ____________________________________________________________________ Have you ever been interviewed as a potential witness in any kind of legal proceeding? Yes No If Yes, please explain: ____________________________________________________________________ Have you ever testified as a witness at any kind of legal proceeding, including a trial? Yes No If Yes, please explain: ____________________________________________________________________ Have you ever testified as an expert witness? Yes No If Yes, please explain and provide area of expertise: ____________________________________________________________________ -12- DOJ-OGR-00005334 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 13 of 35 Juror ID: Have you ever filed a criminal complaint? Yes No If Yes, please explain: Have you ever contacted any prosecutor office: State District Attorney, United States Attorney's Office, State Attorney General? Yes No If Yes, please explain the reason: Have you ever reported someone for wrongdoing to your employer or a government agency? Yes No If Yes, please explain: Other than for a minor traffic citation, have you ever been arrested for, charged with, or convicted of a crime? Yes No If Yes, please explain: MEDIA ISSUES How much do you rely on the following sources for your news? A lot Somewhat Not much Not at all Newspapers: Social Media: Television: Radio: Internet: Conversations: Other: How often do you use or access those sources: Daily Occasionally Rarely -13- Commented [A18]: GOVERNMENT OBJECTION: The Government objects to the 'Media Issues' section proposed by the defense as unnecessary and more prejudicial than probative under the Court's Order. The Government submits that its proposed questions ask the jurors what is necessary on the subject but is not as unduly burdensome as the defendant's proposal. Many of the questions are vague, confusing, and argumentative. Commented [A19R18]: DEFENDANT RESPONSE: A critical purpose of individual voir dire is to ascertain what content the jurors have read and what they think they know about the case. The First Circuit's well-reasoned opinion in In re Tsarnaev, currently pending before the First Circuit, explains why. It is insufficient simply to ask the jurors if they think they can be fair even after seeing media about the case. See, e.g., United States v. Tsarnaev, 968 F.3d 24, (1st Cir. 2020) (failure to ask juror to identify what content they had already read about the case and to identify what they already thought they knew about the grounds for reversal of death sentence), cert. granted, 141 S.Ct. 1683 (Mar. 22, 2021), oral argument scheduled (Oct. 13, 2021); Patriarca v. United States, 402 F.2d 314, 318 (1st Cir. 1968) (judge must elicit 'the kind and degree' of each prospective juror's exposure to the case or the parties 'if asked by counsel'); Smith v. Phillips, 455 U.S. 209, 221-22 (1982) (O'Connor, concurring) ('prospective juror 'may have been tainted in concealing their own bias' or 'may be unaware of it'). Further, as in Tsarnaev, decision, much of the information shown on the media about Ms. Maxwell and Mr. Epstein is either inaccurate or inadmissible, or pertains to persons and charges not before this jury. See, e.g., United States v. Epstein, No. 18-cr-582 (JPO) (ECF No. 267) (granting in part motion to preclude 'largely factual accounts, some of the coverage included inaccurate or inadmissible information — like the details of his un-Mirandized hospital interview and the opinions of public officials that he should die') (citation omitted). It also included a number of individuals' personal opinions regarding Ms. Maxwell's guilt. DOJ-OGR-00005335 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 14 of 35 Juror ID: Please identify by name (all that apply) Newspapers Online News Sources Magazines Radio stations Television/Cable stations Streaming sources (Netflix, Peacock, Amazon, etc.) Podcast providers Internet Sites Social media platform (Facebook, Instagram, Twitter, etc.) Do you belong to any groups on social media (ex. Facebook or WhatsApp groups)? Yes No If Yes, please list the groups: Have you ever posted messages, comments, or opinions on websites/social media, or blogged? Yes No If Yes, please describe the websites or social media platforms that you have used; the types of things you have posted or blogged; and how often you have done it: Do you regularly watch any television shows, movies, dramas, documentaries, or docuseries (on any video platform) involving criminal investigations, crime solving, or criminal trials? Yes No If Yes, please identify the shows: Please indicate your agreement or disagreement with the following: The media can be trusted to report both sides of controversial issues. Strongly agree Agree Disagree Strongly disagree Please identify by name any criminal cases have you followed in the media? -14- DOJ-OGR-00005336 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 15 of 35 Juror ID: This case has been widely reported in the national and local media. There is nothing wrong with having heard something about this case. It is important to truthfully and fully answer all of the following questions. Before coming here today have you read, seen, or heard anything about: Ghislaine Maxwell Yes No Jeffrey Epstein Yes No This Case Yes No How closely have followed any reports about this case, Ghislaine Maxwell or Jeffrey Epstein? Very closely Somewhat closely Not closely Not at all Please indicate the sources from which you have read, seen, heard, or received information about the case, Ghislaine Maxwell or Jeffrey Epstein? (check all that apply) Newspapers Books Magazines Television Radio Streaming Sites (Netflix, Peacock, Amazon, etc.) Podcasts Internet Social Media Chat Rooms Court Proceedings Talked with people Overheard people talking Other Sources (please list) Please identify by name anything you read, viewed, or listened to regarding this case, Ms. Maxwell or Mr. Epstein: News articles Books Television Show Documentaries Docu-Series Podcast -15- DOJ-OGR-00005337 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 16 of 35 Juror ID: Summarize what you know or have heard about this case, Ghislaine Maxwell or Jeffrey Epstein: Please respond to the following based upon anything you have read, seen or heard and discussed with family, friends, colleagues and co-workers, have you formed any impression or opinion about this case? If Yes please state your impressions or opinions: Have you personally formed an opinion about Ms. Maxwell's guilt or innocence as a result of anything you have heard, read or seen? Yes No If Yes, please state summarize your opinion: Have you discussed this case with family, friends, colleagues, or co-workers? No Yes If Yes, summarized what was discussed: Have you verbally stated or posted your opinion on social media about Ms. Maxwell or Mr. Epstein? No Yes If Yes, when and where did you state, or post your opinion? Before today had you read, seen, or heard anything about criminal charges brought against Ms. Maxwell? No Yes If Yes, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a web site): -16- DOJ-OGR-00005338 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 17 of 35 Juror ID: 10. Aside from anything you may have read, seen, or heard about criminal charges brought against Ms. Maxwell, before today, had you read, seen, or heard anything about Ms. Maxwell? Yes No If yes, please state what you remember hearing, and how or from whom you may have heard about Ms. Maxwell (e.g., a friend, the newspaper, a website): 11. Based on anything that you have read, seen, or heard about Ms. Maxwell, including anything about criminal charges against Ms. Maxwell, have you formed any opinions about Ms. Maxwell that might make it difficult for you to be a fair and impartial juror in this case? Yes No Not applicable, I have not read/seen/heard about Ms. Maxwell If yes, please explain why it might be difficult for you to be a fair and impartial juror in this case: 12. Before today, had you read, seen, or heard anything about Jeffrey Epstein? Yes No If yes, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website): -17- DOJ-OGR-00005339 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 18 of 35 Juror ID: 13. Based on anything that you have read, seen, or heard about Jeffrey Epstein, have you formed any opinions about Mr. Epstein that might make it difficult for you to be a fair and impartial juror in this case? Yes No Not applicable, I have not read/seen/heard about Mr. Epstein If yes, please explain why it might be difficult for you to be a fair and impartial juror in this case: 14. Based on anything you have read, seen, or heard about Ms. Maxwell, including anything about criminal charges brought against Ms. Maxwell, would you be able to follow the Court's instruction to put that information out of your mind and decide this case based only on the evidence presented at trial? Yes No Not applicable, I have not read/seen/heard about Ms. Maxwell If no, please explain: When you first learned about this case, what were your reactions? Have your reactions changed since then? Yes No If Yes, please explain: Have you formed any opinion about: Commented [A22]: GOVERNMENT OBJECTION: The Government objects to the next series of questions proposed by the defendant that are in green color font. The Government objects on the grounds that these questions would not provide a basis for a for cause challenge and ask jurors to express opinions based on media coverage. If jurors have had reactions to media coverage, questions about their ability to be fair and impartial will address any questions inappropriately ask jurors to deliberate based on media reporting. Commented [A23R22]: DEFENDANT RESPONSE: The defense incorporates by reference her response to the Government's objection to her "media" related questions and the case law cited therein. -18- DOJ-OGR-00005340 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 19 of 35 Juror ID: This Case Yes No Ghislaine Maxwell Yes No Jeffrey Epstein Yes No If Yes, please summarize your opinion: Have you ever expressed an opinion about this case, Ghislaine Maxwell or Jeffrey Epstein? Yes No If Yes, please summarize what you said: Based on what you have heard, seen, read, or discussed about this case, have you formed an opinion about the guilt or innocence of Ghislaine Maxwell? Definitely Guilty Probably Guilty Probably Not Guilty Definitely Not Guilty Unsure/No Opinion Not enough information to decide Please explain why you feel that way: Have you been contacted in connection with a survey about this case? Yes No If Yes, please explain: Have you been involved in a focus group about this case? Yes No If Yes, please explain: Have you discussed this case with anyone working for the media? Yes No If Yes, please explain what you discussed: How much news have you read or watched about the current case? A lot A little None When was the last time you read, saw, or heard anything related to this case? -19- DOJ-OGR-00005341 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 20 of 35 Juror ID: How accurate do you feel the reports about this case, in any medium, have been? Not accurate Not very accurate Somewhat accurate Very accurate Don't know/No Opinion Do you think Ghislaine Maxwell's association with Jeffrey Epstein will make it difficult for you to fairly and impartially consider the evidence presented at trial and render a verdict based solely on the evidence? Yes No If Yes or Unsure, please explain: If you are selected as a juror in this case, would you be able to refrain from reading about, listening to, or watching any print, electronic media, or Internet coverage in this case? Yes No Unsure If Yes or Unsure, please explain: During the trial, you will hear evidence alleging sex crimes against underage girls. Some of the evidence will involve sexually suggestive or sexually explicit conduct. Is there anything about the nature of this case and the accusations as summarized at the hearing that will make it difficult for you to be a fair and impartial juror in this case? Yes No Unsure If Yes, please explain: Do you have any specific views or feelings concerning laws regarding the age at which individuals can consent to sexual activity with other individuals? No If Yes, what are your views or opinions and would they affect your ability to serve as a fair and impartial juror? Yes No 15. 16. -20- Commented [A29]: The Government proposes the language in purple color font. DOJ-OGR-00005342 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 21 of 35 Juror ID: 17. Do any of you have any opinion about the enforcement of the federal sex trafficking laws or the federal laws concerning sex crimes against minors that might prevent you from being fair and impartial in this case? Yes No If yes, please explain: 18. Have you or a family member ever lobbied, petitioned, or worked in any other manner for or against any laws or regulations relating to sex trafficking or sex crimes against minors? Yes No If yes, please explain when and what you or your family member did: Whether reported or not, have you, any family member or anyone close to you, including a child/minor, ever been the victim of any form of sexual abuse? (This includes actual or attempted sexual assault or other unwanted sexual advance, including by a stranger, acquaintance, supervisor, teacher, or family member.) Yes No If yes, please explain: Whether reported or not, have you, or anyone close to you, including a child/minor, ever felt in danger of being sexually assaulted by another person, including a stranger, acquaintance, supervisor, teacher, or family member? Yes No If yes, please explain: Have you or anyone close to you ever participated in a class or discussion group, read books or articles listened to podcasts, or participated in blogs or chat rooms concerning sexual assault or sexual abuse? Yes No -21- DOJ-OGR-00005343 Commented [A25]: GOVERNMENT OBJECTION: The Government objects to the next series of questions proposed by the defendant that are in green color font. The Government objects on the grounds that these questions are inappropriate, argumentative, confusing, and excessively detailed. The defendant's proposed questions are not streamlined in accordance with the Court's Order. The Government submits that its proposed questions ask the jurors what is necessary on the subject but is not as unduly burdensome as the defendant's proposal. Commented [A26R25]: DEFENDANT RESPONSE: Juror's personal experiences (directly or indirectly through family members and close friends) with sexual misconduct has significant potential to bias their opinions towards Ms. Maxwell based on the allegations and evidence in this case. The privacy of a questionnaire affords an opportunity to share these biases confidentially and candidly best allow the parties to identify who cannot be a fair juror in this case or allows the Court to decide whether individual questioning of that juror is appropriate, based on the sensitive nature of the content of the questions. --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 22 of 35 Juror ID: If Yes, please explain: Have you ever made a claim of inappropriate sexual behavior of any kind (sexual harassment, sexual contact, sexual abuse, or sexual assault/rape)? Yes No If Yes, please explain: Have you ever been accused of any inappropriate sexual behavior of any kind (sexual harassment, sexual contact, sexual abuse, or sexual assault/rape)? Yes No If Yes, please explain: Has your spouse, significant other, any family member, friend, or co-worker ever made a claim of sexual harassment, sexual contact, sexual abuse, or sexual assault/rape? Yes No If Yes, please explain: Has your spouse, significant other, any family member, friend, or co-worker ever been accused of sexual harassment, sexual contact, sexual abuse, or sexual assault/rape? Yes No If Yes, please explain: Have you, any family members or close friends, ever suffered from post-traumatic stress disorder as a result of inappropriate sexual behavior? Yes No Unsure If Yes or Unsure, please explain the cause and, without using any names, identify who was involved: Do you belong to any organizations or groups that have as one of the primary purposes, advocating or promoting federal, state, or local legislation regarding sex abuse? Yes No If Yes, please identify the organization or group Are you active in the organization or group or its activities? Yes No If Yes, describe the extent of involvement and how often Have you, any family member or close friend, ever worked or volunteered at any sex abuse crisis center, sex abuse crisis hot line, sex abuse counseling center, or any related entity? Yes No If Yes, please identify: Are you familiar with political movements in response to sexual abuse, including but not -22- DOJ-OGR-00005344 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 23 of 35 Juror ID: _______ limited to #MeToo, #TimesUp? Yes No If Yes, please explain: _______ Have you, your spouse, significant other, any family, friend, co-worker been involved in or in any way supportive (financially, philosophically or politically) of organizations such as #MeToo, #TimesUp? Yes No If Yes, please explain: _______ Have you ever attended a rally, fundraising event or other events concerning the treatment of women who have been sexually assaulted? Yes No If Yes, please explain: _______ Have you ever contributed money or volunteered time to groups or organizations concerned with women's issue, such as #MeToo, #TimesUp? Yes No If Yes, please explain: _______ Have you or anyone you know had any contact with, worked for, volunteered with, used the services of, or contributed to any entity providing support to individuals claiming to have been sexually abused? Yes No If Yes, please explain: _______ This case involves allegations of sexual assault and sex trafficking of minors. Would you feel uncomfortable if you are selected to sit on this case? Yes No If No, is there any experience that you or anyone close to you has had that may affect your ability to listen to the evidence and reach a fair verdict based only on the evidence or lack of evidence? Yes No If Yes, please explain: _______ Is there any experience that you or anyone close to you has had that may affect how you might view a case such as this Yes No If Yes, please explain: _______ -23- DOJ-OGR-00005345 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 24 of 35 Juror ID: Do you believe that anyone who discloses having been sexually abused must be telling the truth? Yes No Unsure If Yes or Unsure, please explain: Would you tend to believe the testimony of a woman claiming sexual abuse more, less, or the same as any other witness? Believe more Believe less Believe the same Unsure Would you tend to believe the testimony of a defendant accused of sexual abuse more, less, or the same as any other witness? Believe more Believe less Believe the same Unsure Have you ever been involved—as defendant, victim, or any way—in a case involving sex trafficking or sex crimes against minors? Yes No If yes, without listing names, please explain the nature of the allegations, the approximate date(s), and the outcome, and indicate whether that would affect your ability to serve as a fair and impartial juror in this case: Has a relative, close friend, or associate ever been involved—as defendant, victim, or any way—in a case involving sex trafficking or sex crimes against minors? Yes No If yes, without listing names, please explain the nature of the allegations, the approximate date(s), and the outcome, and indicate whether that would affect your ability to serve as a fair and impartial juror in this case: Have you ever been the victim of sexual abuse of any nature? Yes No If yes, please explain, and indicate whether that would affect your ability to serve as a fair and impartial juror in this case: Commented [A271]: The Government proposes the language in purple color font 19. Yes 20. Yes 21. Yes DOJ-OGR-00005346 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 25 of 35 Juror ID: ______________________________________ MENTAL HEALTH, LAW, LAW ENFORCEMENT Have you, your spouse or significant other, family or close friends ever studied or received any mental health training? Yes No If Yes, please explain: ______________________________________ Have you ever had any employment or volunteer experience in any of the following areas? (Check each one that applies) Psychiatry Psychology Social Work Mental Health Therapy/Counseling Sex Abuse Counseling Do you have any family or friends who are psychiatrists, psychologists, mental health therapists/counselors or sex abuse counselors? Yes No If Yes, do you often discuss their work with them? ______________________________________ Have you received any training in law, law enforcement or criminology? Yes No If Yes, please explain: ______________________________________ Have you ever had any employment or done any volunteer work in any of the following areas? (Check each one that applies to you) Law Enforcement Investigations Corrections/Jail/Prison Legal Profession Prosecution Criminal Defense Justice System/Courts Local/State/Federal Government Do you have any family or friends who are in the legal or law enforcement profession? Yes No If Yes, do you often discuss their work with them? ______________________________________ Would you believe the testimony of a law enforcement officer simply because he/she is a law enforcement officer? Yes No If yes, please explain: ______________________________________ Would you favor the side that had law enforcement officers as witnesses? Yes No -25- DOJ-OGR-00005347 Commented [A28]: GOVERNMENT OBJECTION: The defendant has proposed additional questions in this section in addition to the questions proposed below on consent. The additional questions proposed by the defendant are duplicative, unnecessarily burdensome, and overly detailed. In addition, questions about experience with mental health issues are not designed to screen for bias and are not appropriate for inclusion in a written questionnaire. Commented [A29R28]: DEFENDANT RESPONSE: The defense-proposed questions are designed to identify individuals whose training, education and employment may cause the juror to follow their own independent knowledge and not follow the evidence actually presented at trial, or may reveal biases in favor of the Government. --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 26 of 35 Juror ID: If yes, please explain: 22. Do you or any member of your family or a close friend work in law, law enforcement, the justice system, or the courts? Yes No If yes, please explain, and indicate whether that would affect your ability to serve as a fair and impartial juror in this case: 23. Do you know or have any association—professional, business, or social, direct or indirect—with any member of the staff of the United States Attorney's Office for the Southern District of New York? Yes No If yes, please explain, and indicate whether that would affect your ability to serve as a fair and impartial juror in this case: 24. Do you know or have any association—professional, business, or social, direct or indirect—with the Federal Bureau of Investigation, commonly known as the FBI? Yes No If yes, please explain, and indicate whether that would affect your ability to serve as a fair and impartial juror in this case: 25. Do you know or have any association—professional, business, or social, direct or indirect—with the New York City Police Department, commonly known as the NYPD? Yes No If yes, please explain, and indicate whether that would affect your ability to serve as a fair and impartial juror in this case: -26- DOJ-OGR-00005348 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 27 of 35 Juror ID: 26. Have you, either through any experience you have had or anything you have seen or read, developed any bias or prejudice or other feelings for or against the United States Department of Justice, the United States Attorney's Office for the Southern District of New York, the FBI, or the NYPD? Yes No If yes, please explain: 27. Do you have any opinion of the U.S. Attorney's Office for the Southern District of New York or the U.S. Attorney Damian Williams that might make it difficult for you to be a fair and impartial juror in this case? Yes No If yes, please explain: 28. Do you have any opinions about prosecutors or criminal defense attorneys generally that might make it difficult for you to be a fair and impartial juror in this case? Yes No If yes, please explain: -27- DOJ-OGR-00005349 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 28 of 35 Juror ID: _______ 29. Do you have any opinion about the criminal justice system generally or the federal criminal justice system in particular that might make it difficult for you to be a fair and impartial juror in this case? Yes No If yes, please explain: ____________________________________________________ ____________________________________________________ ____________________________________________________ ____________________________________________________ CLOSING QUESTIONS Do you think Ghislaine Maxwell's association with Jeffrey Epstein will make it difficult for you fairly and impartially consider the evidence presented at trial and render a verdict based solely on the evidence? Yes No Unsure If Yes or Unsure, please explain: ____________________________________________________ Do you think what you have heard, seen, and read about Ghislaine Maxwell make it difficult for you fairly and impartially consider the evidence presented at trial and render a verdict based solely on the evidence? Yes No Unsure If Yes or Unsure, please explain: ____________________________________________________ If you were a party to this case - either the prosecution or Ms. Maxwell - is there any reason you would not want yourself to be a juror? Yes No Unsure If Yes or Unsure, please explain: ____________________________________________________ Some people who are called for possible jury service want to be chosen while others do not. How do you personally feel? (Please check one.) Very strongly want to serve Somewhat want to serve Indifferent Opposed to serving Strongly opposed to serving Would be difficult to serve Please explain your feelings: ____________________________________________________ If you were convinced, at the conclusion of the trial, that Ms. Maxwell is either guilty or not guilty of the crimes charged, and a majority of the jurors disagreed with you, would you not change your verdict simply because you were in the minority? Yes No Unsure If Yes or Unsure, please explain: ____________________________________________________ Is there anything that has come up in this questionnaire that creates doubt in your mind about whether you could be a fair, objective, and impartial juror in this particular case? Yes No Commented [A30]: GOVERNMENT OBJECTION: The Government objects to the questions proposed by the defendant in the "Closing Questions" section. The Government does not believe these questions should be included in the written questionnaire because these questions will not provide a basis for a for-cause challenge. Some of the questions proposed by the defendant are duplicative of prior questions. Many of the questions are inappropriate, argumentative, confusing, and excessively detailed. Commented [A31R30]: DEFENDANT RESPONSE: The questions are designed to identify persons for whom a for-cause challenge may be sustained by this Court. The Government has not identified any particular question that is "inappropriate, argumentative, confusing, and excessively detailed," nor have they proposed limiting language that would cure any such problem. DOJ-OGR-00005350 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 29 of 35 Juror ID: If yes, please explain: Is there anything else the Court or the parties should know about you as a prospective juror in this case? Please state any reason why you believe you could not or should not serve as a juror in this case: Is there anything not covered in this questionnaire that you feel the Court or the attorneys should know, so that your ability to be a fair and impartial juror can be evaluated? Yes No If yes, please explain: Do you believe you should not serve as a juror in this case? Yes No Unsure If Yes or Unsure, please explain: Do you believe you should serve as a juror in this case? Yes No Unsure If Yes or Unsure, please explain: Is there anything else that you think the Court or parties should know that might influence your ability to fairly and impartially judge the evidence in this case and to apply the law as instructed by the Court? Yes No Unsure If Yes or Unsure, please explain: Is there anything that would cause you to not to want to sit on a jury in a case involving allegation of sexual assault and sex trafficking of minors? Yes No Unsure Is there anything about this case, Ms. Maxwell or Epstein that would cause you not to want to be a juror in this case? Yes No Unsure If Yes or Unsure, please explain: Is there anything about this case, Ms. Maxwell or Epstein that would cause you to want to be a juror in this case? Yes No Unsure If Yes or Unsure, please explain: Given the high-profile nature of this case and the sensitive nature of the charges, is there any reason why you would feel pressure (personally, professionally, politically, philosophically, or religiously) to return a verdict other than one based only on the evidence? Yes No Unsure If Yes or Unsure, please explain: -29- DOJ-OGR-00005351 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 30 of 35 Juror ID: Is there anything about the subject matter of this case, or the points covered in this questionnaire, which creates a question in your mind as to whether you could be a fair, objective, and impartial juror in this particular case? Yes No If Yes, please explain: When the time comes for individual oral questioning of prospective jurors, you will have the opportunity to discuss privately with the Court and the attorneys in the case any answers which would require you to reveal information you feel is personal and private and which you do not want to reveal publicly in open court. Would any of the questions above require you to reveal confidential and personal information which you would like to keep private? Yes No If Yes, please list which question number(s): Is there any matter you wish to discuss privately with the Judge? Yes No If Yes, please explain: Is there anything else the attorneys or the Court might want to know about you when considering you as a juror in this case? Yes No If Yes, please explain: As a juror it is important that you do not obtain information about this case outside of the courtroom. The Court will instruct you that you are not to watch television, go on the internet, read newspapers, magazines, or any other form of print media, listen to or watch any media coverage, use social media, and/or speak to anyone regarding this case and that the only evidence you are permitted to consider is that which is presented in court. Will you be tempted to disregard this instruction? Yes No If Yes, please explain: If the court instructs you not to discuss the case with anyone until it is finally submitted to you for deliberation at the end of the trial, and then to only discuss it with your fellow jurors in the jury room, would you have difficulty in following that instruction? Yes No If Yes, please explain: -30- DOJ-OGR-00005352 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 31 of 35 Juror ID: ____________ DECLARATION I, ____________ (juror number) declare under penalty of perjury that the foregoing answers set forth in this Jury Questionnaire are true and correct to the best of my knowledge and belief. I have not discussed my answers with others, or received assistance in completing the questionnaire. Signed this ____ day of November, 2021 -31- DOJ-OGR-00005353 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 32 of 35 Juror ID: You may use these pages to finish any answers that you could not fit in the spaces provided above. If you write anything below, please indicate the number of the relevant question. -32- DOJ-OGR-00005354 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 33 of 35 Juror ID: ____________________________________________________________________________________ -33- DOJ-OGR-00005355 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 34 of 35 Juror ID: -34- DOJ-OGR-00005356 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 35 of 35 Juror ID: -35- DOJ-OGR-00005357