Document 638

COURT CAS#: 20-cr-00330-PAE Document 638 Filed 03/09/22 Page 1 of 29 USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 3/9/22 DATE: 3/8/22 TIME: CASE: 20cr330, US v. Maxwell Juror ID: 50 Post-verdict hearing PRELIMINARY INSTRUCTIONS Please read the following instructions carefully before completing any portion of this questionnaire. Please print your juror number in the space provided at the top of each page. Do not write your name on the questionnaire. Please answer each and every question fully. Some questions have more than one part. YOU ARE SWORN TO GIVE TRUE AND COMPLETE ANSWERS TO ALL QUESTIONS IN THIS QUESTIONNAIRE. This questionnaire is designed to help simplify and shorten the jury selection process. The purpose of the questionnaire is to determine whether prospective jurors can decide this case impartially based upon the evidence presented at trial and the legal instructions given by the presiding judge. The questions are not intended to inquire unnecessarily into personal matters. Although some of the questions may appear to be of a personal nature, please understand that the Court and the parties must learn enough information about each juror's background and experiences to select a fair and impartial jury. Please answer all questions to the best of your ability. If you do not know the answer to a question then write, "I don't know." There are no "right" or "wrong" answers, only truthful answers. If you have strong feelings about this case in general, please do not hesitate to share them. Although you may be a perfectly good juror in another case, this may or may not be the right case for you to sit on as an impartial juror. Both parties have the right to get honest answers and to hear your true opinions. Do not discuss the case or your answers with anyone. It is important that the answers be yours alone. Remember, you are sworn to give true and complete answers to all questions. If you need extra space to answer any question, please use the extra blank sheets of paper included at the end of the questionnaire. Be sure to indicate on the blank page the number of the question you are answering. Do not write anything on the back of any page. DO NOT DISCUSS YOUR QUESTIONS AND ANSWERS OR THE CASE WITH ANYONE, NOW OR UNTIL FURTHER INSTRUCTED BY THE COURT. You should not discuss the questions or answers with fellow jurors. It is very important that your answers be your own individual answers. More broadly, do not discuss the case with anyone, including the lawyers (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, in magazines, on the radio or television, or on the Internet. DO NOT DO YOUR OWN RESEARCH ON THE CASE. Do not conduct any research into the case (or anyone participating in the case) at any time before your entire jury service has been completed. That includes performing Internet searches, asking other people about the case, reading news stories, books, or reports about the case, or watching films or television programs that relate to the case. Do not read, watch, or listen to any information about this case. -3- DOJ-OGR-00009662 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 2 of 29 Juror ID: 50 Your name will not be disclosed or connected to this questionnaire beyond the Judge and the parties in this case. However, if you believe that any of your answers contain private information that could embarrass you or otherwise seriously compromise your privacy and wish to request that the Court keep them confidential and not distribute them beyond the Judge and parties, please indicate the particular question number at the end of the questionnaire. 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 six weeks. This is a criminal case. The Defendant, Ghislaine Maxwell, has been charged in an Indictment with various criminal offenses. The Indictment is not evidence. It simply contains the charges—referred to as “counts”—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 travel to engage in criminal sexual activity, to transport minors to engage in criminal sexual activity, and to engage 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 and others to entice minors to travel to engage in sexual activity for which a person can be charged with a criminal offense. Count Two charges the Defendant with enticing a minor to travel to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Three charges the Defendant with conspiring with Epstein and others to transport minors to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Four charges the Defendant with transporting a minor to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. 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. 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. -4- DOJ-OGR-00009663 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 3 of 29 Juror ID: 50 SCHEDULE Potential jurors will be called back for further questioning and jury selection from Tuesday, November 16, 2021, through Friday, November 19, 2021. Your availability during that week will be required. The trial will commence on Monday, November 29, 2021. The trial is expected to last about six weeks. Generally, trial will be held five days per week, Monday through Friday, from 9:30 a.m. until 5:00 p.m. Trial will not be held on Friday, December 24, 2021 (Christmas Eve Day) and Friday, December 31, 2021 (New Year's Eve). If you are selected as a juror, you will be required to be present for the taking of testimony and evidence for as long as the trial lasts. There are no plans to sequester the jury, which means you will go home every day after court. All jury service involves some degree of hardship. Our court and justice system depends on citizens doing their civic duty to serve as jurors, which involves temporarily putting aside their regular business for jury service. The Court views service on a jury to be one of the highest duties a citizen owes to the United States. Mere inconvenience or the usual financial hardship of jury service will not be sufficient to excuse a prospective juror. You must show extraordinary personal or financial hardship to be excused from service. -5- DOJ-OGR-00009664 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 4 of 29 Juror ID: 50 PLEASE ANSWER THE FOLLOWING QUESTIONS: ABILITY TO SERVE Please note: In the event you are excused from service on this jury, you will likely 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. 1. Do you have any unmovable commitments between November 16, 2021, and November 19, 2021, which is when jury selection will take place? Yes No 1a. If yes, please explain (without indicating the name of where you work or the names of any family members or friends, or other personal information that might identify who you are): ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________ 2. Do you have any unmovable commitments between November 29, 2021, and approximately January 15, 2022, which is the estimated length for trial? Yes No 2a. If yes, please explain (without indicating the name of where you work or the names of any family members or friends, or other personal information that might identify who you are): ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________ 3. Do you have any international travel plans between now and November 29, 2021? Yes No 4. Do any circumstances exist such that serving on the jury in this case would entail serious hardship or extreme inconvenience? Yes No 4a. If yes, please briefly describe the serious hardship or extreme inconvenience: ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________ -6- DOJ-OGR-00009665 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 5 of 29 Juror ID: 50 5. 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 5:00 p.m.? (Please note, the Court will arrange and provide transportation to and from the Courthouse each day for selected jurors). Yes No 5a. If yes, please explain why you would be unable to get to court by 9:30 a.m. or remain until 5:00 p.m.: 6. Do you have any difficulty reading, speaking, or understanding English? Yes No 7. 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 7a. 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. 8. Are you taking any medication which would prevent you from giving full attention to all the evidence at this trial? Yes No 8a. If yes, please explain: -7- DOJ-OGR-00009666 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 6 of 29 Juror ID: 50 9. Do you have any religious, philosophical, or other beliefs that would make you unable to render a verdict in a criminal case? Yes No 9a. If yes, please explain: BASIC LEGAL PRINCIPLES AND MEDIA RESTRICTIONS 10. Under the law, the facts are for the jury to determine and the law is for the Judge to determine. You are required to accept the law as the Judge explains it to you even if you do not like the law or disagree with it, and you must determine the facts according to those instructions. Do you accept this principle, and will you be able to follow the Judge's instructions if selected to serve on this jury? Yes No 10a. If no, please explain: 11. The law provides that a defendant in a criminal case is presumed innocent at all stages of the trial and is not required to put on any defense at all. The Government is required to prove the defendant guilty beyond a reasonable doubt on each charge. Do you accept these principles, and will you be able to apply them if selected to serve on this jury? Yes No 11a. If no, please explain: -8- DOJ-OGR-00009667 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 7 of 29 Juror ID: 50 12. The law provides that a defendant in a criminal case has an absolute right not to testify, and that a juror cannot hold it against the defendant if she chooses not to testify. Do you accept this principle, and will you be able to apply it if selected to serve on this jury? Yes No 12a. If no, please explain: 13. A juror is required by law to make his or her decision based solely on the evidence or lack of evidence presented in Court, and not on the basis of conjecture, suspicion, bias, sympathy, or prejudice. Do you accept this principle, and will you be able to apply it if selected to serve on this jury? Yes No 13a. If no, please explain: 14. Under the law, the question of punishment is for the Court alone to decide, and thus the issue of punishment must not enter into your deliberations as to whether the defendant is guilty or not guilty as charged. Do you accept this principle, and will you be able to apply it if selected to serve on this jury? Yes No 14a. If no, please explain: -9- DOJ-OGR-00009668 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 8 of 29 Juror ID: 50 15. You may hear testimony in this case that law enforcement officers recovered certain evidence from searches. The Court will instruct you that those searches were legal and that the evidence obtained from those searches is admissible in this case. Do you have any feelings or opinions about searches conducted by law enforcement officers, or the use of evidence obtained from searches, that would affect your ability to be fair and impartial in this case? Yes No 15a. If yes, please explain: 16. You also may hear testimony in this case from expert witnesses. Have you had any experiences with experts, or do you have any general feelings about the use of experts, that would affect your ability to be fair and impartial in this case? Yes No 16a. If yes, please explain: 17. As instructed above, from now and until your jury service is complete, you are instructed to avoid all media coverage and not to go on the Internet with regard to this case for any purpose. That is, you are forbidden from consuming any news media or social media, or any discussion of this case (or of anyone participating in the case) outside of the courtroom whatsoever. You also must not discuss this case with anyone. This includes your family, friends, spouse, domestic partner, colleagues, and co-workers. These instructions apply from now and until you are either dismissed from jury selection or chosen as a juror and the trial is complete. When we return for the next step in jury selection, the Judge will ask you if you have followed this instruction. Do you have any reservations or concerns about your ability or willingness to follow this instruction? Yes No -10- DOJ-OGR-00009669 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 9 of 29 Juror ID: 50 17a. If yes, please explain: 18. Have you ever served as a juror in a trial in any court? Yes No 19. Have you ever at any time served as a member of a grand jury, whether in federal, state, county, or city court? Yes No EXPERIENCE AS A WITNESS, DEFENDANT, OR CRIME VICTIM 20. Have you, or has any relative or close friend, ever participated in a state or federal court case, whether criminal or civil, as a witness, plaintiff, or defendant? Yes (self) Yes (friend or family member) No 20a. If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case? Yes No 20b. If yes to 20a, please explain: 21. Have you or any relative or close friend ever been involved or appeared as a witness in any investigation by a federal or state grand jury or by a congressional or state legislative committee, licensing authority, or governmental agency, or been questioned in any matter by any federal, state, or local law enforcement agency? Yes (self) Yes (friend or family member) No -11- DOJ-OGR-00009670 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 10 of 29 Juror ID: 50 21a. If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case? Yes No 21b. If yes to 21a, please explain: 22. Have you, or has any relative or close friend, ever been subpoenaed for any inquiry or investigation? Yes (self) Yes (friend or family member) No 22a. If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case? Yes No 22b. If yes to 22a, please explain: 23. Have you, or has any relative or close friend, ever been arrested or charged with a crime? Yes (self) Yes (friend or family member) No 23a. If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case? Yes No 23b. If yes to 23a, please explain: -12- DOJ-OGR-00009671 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 11 of 29 50 Juror ID: 24. Have you, or has any relative or close friend, ever been the subject of any investigation or accusation by any grand jury, state or federal, or any other investigation? □ Yes (self) □ Yes (friend or family member) ☒ No 24a. If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case? □ Yes □ No 24b. If yes to 24a, please explain: ____________________________________________________ ____________________________________________________ ____________________________________________________ 25. Have you, or any of your relatives or close friends, ever been a victim of a crime? □ Yes (self) □ Yes (friend or family member) ☒ No 25a. If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case? □ Yes □ No 25b. If yes to 25a, please explain: ____________________________________________________ ____________________________________________________ ____________________________________________________ 26. Have you, or has any member of your family or any of your close friends—either as individuals or in the course of their business affairs—ever been a party to a legal action or dispute with the United States, or with any of the officers, departments, agencies, or employees of the United States, including the United States Attorney's Office, the FBI, or the NYPD? □ Yes (self) □ Yes (friend or family member) ☒ No -13- DOJ-OGR-00009672 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 12 of 29 Juror ID: 50 26a. If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case? Yes No 26b. If yes to 26a, please explain: 27. Have you, or has any member of your family, ever had a dispute concerning money owed to you by the Government or owed by you to the Government? Yes (self) Yes (friend or family member) No 27a. If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case? Yes No 27b. If yes to 27a, please explain: RELATIONSHIP WITH, AND VIEW OF, GOVERNMENT, DEFENSE, AND OTHERS 28. 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 28a. If yes, please explain: -14- DOJ-OGR-00009673 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 13 of 29 Juror ID: 50 28b. If yes to 28, would this affect your ability to serve as a fair and impartial juror in this case? Yes No 28c. If yes to 28b, please explain: 29. 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 29a. If yes, please explain: 29b. If yes to 29, would this affect your ability to serve as a fair and impartial juror in this case? Yes No 29c. If yes to 29b, please explain: 30. 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 30a. If yes, please explain: -15- DOJ-OGR-00009674 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 14 of 29 Juror ID: 50 30b. If yes to 30, would this affect your ability to serve as a fair and impartial juror in this case? Yes No 30c. If yes to 30b, please explain: 31. 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 31a. If yes, please explain: 31b. If yes to 31, would this affect your ability to serve as a fair and impartial juror in this case? Yes No 31c. If yes to 31b, please explain: 32. Do you have any opinion of the U.S. Attorney's Office for the Southern District of New York, the U.S. Attorney Damian Williams, or the former Acting U.S. Attorney Audrey Strauss that might make it difficult for you to be a fair and impartial juror in this case? Yes No -16- DOJ-OGR-00009675 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 15 of 29 Juror ID: 50 32a. If yes, please explain: PERSONAL RELATIONSHIP WITH CASE PARTICIPANTS 33. The next subset of questions asks whether you or any member of your family or a close friend personally knows or has past or present dealings with individuals involved in this case. To "personally know" means to have some direct or personal knowledge or connection to the following individuals. If you have only heard names through media or social media, for example, that is not personal knowledge. 33a. Do you or does any member of your family or a close friend personally know or have past or present dealings with the Defendant in this case, Ghislaine Maxwell, or her family members? Yes No 33b. Do you or does any member of your family or a close friend personally know or have past or present dealings with Jeffrey Epstein? Yes No 33c. Do you or does any member of your family or a close friend personally know or have past or present dealings with the U.S. Attorney for the Southern District of New York, Damian Williams, the former Acting U.S. Attorney for the Southern District of New York, Audrey Strauss, 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 33d. 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 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 -17- DOJ-OGR-00009676 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 16 of 29 Juror ID: 50 33e. 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 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 33f. Do you or does any member of your family or a close friend personally know or have past or present dealings with the United States District Court Judge who is presiding over this case, Alison J. Nathan, or anyone who works on her staff? Yes No 33g. If you answered "yes" to any of the above sub-questions (33a, 33b, 33c, 33d, 33e, or 33f), 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: -18- DOJ-OGR-00009677 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 17 of 29 Juror ID: 50 KNOWLEDGE OF CASE AND PEOPLE 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 answer all of the following questions truthfully and fully. 34. Before today, had you read, seen, or heard anything about Ms. Maxwell? Yes No Unsure 34a. If yes or unsure, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website, social media). If you heard about Ms. Maxwell from a media source, please identify the media source by name: I read on a website that she was Jeffrey Epsteins girlfriend - source was CNN.com 35. Have you personally formed an opinion about Ms. Maxwell's guilt or innocence of the crimes charged as a result of anything you have heard, read or seen? Yes No Unsure Not applicable, I have not read/seen/heard about Ms. Maxwell 35a. If yes or unsure, please summarize your opinion: -19- DOJ-OGR-00009678 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 18 of 29 Juror ID: 50 36. 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 Unsure Not applicable, I have not read/seen/heard about Ms. Maxwell 36a. If yes or unsure, please explain why it might be difficult for you to be a fair and impartial juror in this case: 37. Before today, had you read, seen, or heard anything about Jeffrey Epstein? Yes No Unsure 37a. If yes or unsure, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website, social media). If you heard about Mr. Epstein from a media source, please identify the media source by name: CNN's source. Heard about his death and that he was in jail awaiting trial. 38. Have you verbally stated or posted your opinion on social media or online about Ms. Maxwell or Mr. Epstein? Yes No Not applicable, I have not read/seen/heard about Mr. Epstein/Ms. Maxwell 38a. If yes, when and where did you state or post your opinion? -20- DOJ-OGR-00009679 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 19 of 29 Juror ID: 50 39. 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 Unsure Not applicable, I have not read/seen/heard about Mr. Epstein 39a. If yes or unsure, please explain why it might be difficult for you to be a fair and impartial juror in this case: 40. If you have heard about Jeffrey Epstein, do you think Ms. Maxwell's alleged 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 Unsure Not applicable, I have not read/seen/heard about Ms. Maxwell and/or Jeffrey Epstein 40a. If yes or unsure, please explain: 41. 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 Unsure Not applicable, I have not read/seen/heard about Ms. Maxwell -21- DOJ-OGR-00009680 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 20 of 29 Juror ID: 50 41a. If no or unsure, please explain: NATURE OF CHARGES 42. During the trial, you will hear evidence alleging sex crimes against underage girls. Some of the evidence in this case will involve sexually suggestive or sexually explicit conduct. Is there anything about the nature of this case and the accusations as summarized at the beginning of this questionnaire that might make it difficult for you to be a fair and impartial juror in this case? Yes No 42a. If yes, please explain: 43. Do you have any specific views or feelings concerning laws regarding the age at which individuals can or cannot consent to sexual activity with other individuals that would affect your ability to serve as a fair and impartial juror? Yes No 43a. If yes, please explain: 44. Do 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 -22- DOJ-OGR-00009681 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 21 of 29 Juror ID: 50 44a. If yes, please explain: 45. Have you or a family member ever supported, lobbied, petitioned, protested, or worked in any other manner for or against any laws, regulations, or organizations relating to sex trafficking, sex crimes against minors, sex abuse, or sexual harassment? Yes No 45a. If yes, please explain when and what you or your family member did: 45b. If your answer to 45 was yes, do you believe that this would affect your ability to serve fairly and impartially as a juror in this case? Yes No 45c. If yes to 45b, please explain: 46. The witnesses in this case may include law enforcement witnesses. Would you have any difficulty assessing the credibility of a law enforcement officer just like you would any other witness? Yes No 46a. If yes, please explain: -23- DOJ-OGR-00009682 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 22 of 29 Juror ID: 50 47. Witnesses in this case may testify claiming sexual abuse or sexual assault. Would you have any difficulty assessing the credibility of a witness claiming sexual assault or abuse just like you would any other witness? Yes No 47a. If yes, please explain: 48. Have you or a friend or family member ever been the victim of sexual harassment, sexual abuse, or sexual assault? (This includes actual or attempted sexual assault or other unwanted sexual advance, including by a stranger, acquaintance, supervisor, teacher, or family member.) Yes (self) Yes (friend or family member) No 48a. If yes, without listing names, please explain: 48b. If your answer to 48 was yes, do you believe that this would affect your ability to serve fairly and impartially as a juror in this case? Yes No 48c. If yes to 48b, please explain: -24- DOJ-OGR-00009683 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 23 of 29 Juror ID: 50 49. Have you or a friend or family member ever been accused of sexual harassment, sexual abuse, or sexual assault? (This includes both formal accusations in a court of law or informal accusations in a social or work setting of actual or attempted sexual assault or other unwanted sexual advance, including by a stranger, acquaintance, supervisor, teacher, or family member.) Yes (self) Yes (friend or family member) X No 49a. If yes, without listing names, please explain: 49b. If your answer to 49 was yes, do you believe that this would affect your ability to serve fairly and impartially as a juror in this case? Yes No 49c. If yes to 49b, please explain: 50. Is there any other experience that you or anyone close to you has had that may affect your ability to serve fairly and impartially as a juror in this case? Yes X No 50a. If yes, please explain: -25- DOJ-OGR-00009684 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 24 of 29 Juror ID: 50 CLOSING QUESTION 51. Do you wish for any particular answers to remain confidential and to not go beyond the Judge, counsel, and the Defendant, because the answer would embarrass you or otherwise seriously compromise your privacy? Yes No If yes, please list which question number(s): -26- DOJ-OGR-00009685 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 25 of 29 Juror ID: 50 DECLARATION I, Juror Number 50 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 4th day of November, 2021 DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER. -27- DOJ-OGR-00009686 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 26 of 29 Juror ID: 50 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. -28- DOJ-OGR-00009687 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 27 of 29 Juror ID: 50 -29- DOJ-OGR-00009688 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 28 of 29 Juror ID: 50 -30- DOJ-OGR-00009689 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 638 Filed 03/09/22 Page 29 of 29 Juror ID: 50 -31- DOJ-OGR-00009690