Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 6 of 353
Juror ID: 2
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.
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DOJ-OGR-00010759
Full Text
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 6 of 353
Juror ID: 2
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.
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DOJ-OGR-00010759
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 7 of 353 Juror ID: 2 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. 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-00010760
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 8 of 353
Juror ID: 2
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.
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DOJ-OGR-00010761
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 9 of 353 Juror ID: 2 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-00010762
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 10 of 353 Juror ID: 2 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.: Definitely Not 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. Definitely Know 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: Doctor Excused -7- DOJ-OGR-00010763
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 11 of 353 Juror ID: 2 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-00010764
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 12 of 353 Juror ID: 2 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-00010765
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 13 of 353
Juror ID: 2
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
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DOJ-OGR-00010766
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 14 of 353 Juror ID: 2 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-00010767
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 15 of 353 Juror ID: 2 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-00010768
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 16 of 353 Juror ID: 2 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-00010769
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 17 of 353 Juror ID: 2 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-00010770
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 18 of 353 Juror ID: 2 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-00010771
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 19 of 353
Juror ID: 2
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
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DOJ-OGR-00010772
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 20 of 353 Juror ID: 2 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 the 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-00010773
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 21 of 353
Juror ID: 2
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:
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DOJ-OGR-00010774
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 22 of 353 Juror ID: 2 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: Channel 2 news 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-00010775
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 23 of 353
Juror ID: 2
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:
New York Evening News
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?
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DOJ-OGR-00010776
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 24 of 353 Juror ID: 2 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-00010777
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 25 of 353 Juror ID: 2 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-00010778
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 26 of 353 Juror ID: 2 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-00010779
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 27 of 353 Juror ID: 2 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-00010780
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 28 of 353
Juror ID: 2
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) 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 No
50a. If yes, please explain:
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DOJ-OGR-00010781
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 29 of 353 Juror ID: 2 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):
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 30 of 353
Juror ID: 2
DECLARATION
I, Juror Number 2 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 2 day of November, 2021
DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER.
2
-27-
DOJ-OGR-00010783
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 31 of 353 Juror ID: 2 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-00010784
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 32 of 353 Juror ID: 8 -29- DOJ-OGR-00010785
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 33 of 353 Juror ID: 2 -30- DOJ-OGR-00010786
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 34 of 353 Juror ID: 2 -31- DOJ-OGR-00010787
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 35 of 353
Juror ID: 7
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-00010788
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 36 of 353
Juror ID: 7
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. 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-00010789
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 37 of 353 Juror ID: 7 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-00010790
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 38 of 353 Juror ID: 7 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-00010791
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 39 of 353
Juror ID: 1
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-00010792
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 40 of 353 Juror ID: 7 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: 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-00010793
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 41 of 353
Juror ID: 7
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-00010794
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 42 of 353
Juror ID: 1
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-00010795
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 43 of 353 Juror ID: 7 17a. If yes, please explain: ______________________________________ ______________________________________ ______________________________________ ______________________________________ PRIOR JURY SERVICE 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-00010796
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 44 of 353 Juror ID: 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-00010797
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 45 of 353
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:
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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:
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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-00010798
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 46 of 353 Juror ID: 7 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: MOTHER ADMIN SUPERVISOR -14- DOJ-OGR-00010799
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 47 of 353 Juror ID: 7 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-00010800
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 48 of 353 Juror ID: 1 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: MOTHER ADMIN 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-00010801
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 49 of 353 Juror ID: 7 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 the 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-00010802
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 50 of 353
Juror ID: ___________________________________
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:
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-18-
DOJ-OGR-00010803
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 51 of 353 Juror ID: 1 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: 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-00010804
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 52 of 353
Juror ID: 1
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:
HE PASSED AWAY IN PRISON
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-00010805
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 53 of 353
Juror ID: ___________________________________
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:
____________________________________________________________________
____________________________________________________________________
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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:
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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-00010806
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 54 of 353 Juror ID: 7 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-00010807
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 55 of 353
Juror ID: 2
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-00010808
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 56 of 353 Juror ID: 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-00010809
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 57 of 353 Juror ID: 1 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) No If yes, without listing names, please explain: 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 If yes to 49b, please explain: 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 No If yes, please explain: -25- DOJ-OGR-00010810
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 58 of 353 Juror ID: 1 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-00010811
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 59 of 353
Juror ID: 7
DECLARATION
I, Juror Number 7 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-00010812
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 60 of 353 Juror ID: 1 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-00010813
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 61 of 353 Juror ID: 7 -29- DOJ-OGR-00010814
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 62 of 353 Juror ID: -30- DOJ-OGR-00010815
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 63 of 353 Juror ID: 1 -31- DOJ-OGR-00010816
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 64 of 353
Juror ID: 26
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-00010817
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Juror ID: 26
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. 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-00010818
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Juror ID: 26
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-00010819
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 67 of 353 Juror ID: 26 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-00010820
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 68 of 353 Juror ID: 26 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-00010821
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Jury ID: 26
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-00010822
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Juror ID: 26
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-00010823
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Juror ID: 26
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-00010824
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Juror ID: 26
17a. If yes, please explain:
PRIOR JURY SERVICE
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-00010825
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 73 of 353 Juror ID: 26 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-00010826
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 74 of 353 Juror ID: 26 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-00010827
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 75 of 353 Juror ID: 26 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: I work as an Admin. Contract Specialist. -14- DOJ-OGR-00010828
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 76 of 353 Juror ID: 76 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-00010829
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 77 of 353 Juror ID: 26 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: I work with Admin. Contract Specialist. 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-00010830
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 78 of 353 Juror ID: 26 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 the 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-00010831
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Juror ID: 26
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:
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-18-
DOJ-OGR-00010832
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 80 of 353 Juror ID: 26 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: ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________ 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-00010833
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 81 of 353 Juror ID: 26 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: I saw on television media that Mr. Epstein was accused of sex trafficking. 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-00010834
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 82 of 353 Juror ID: 26 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-00010835
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 83 of 353 Juror ID: 24 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-00010836
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 84 of 353 Juror ID: 26 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-00010837
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 85 of 353 Juror ID: 26 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-00010838
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 86 of 353 Juror ID: 20 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) No If yes, without listing names, please explain: 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 If yes to 49b, please explain: 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 No If yes, please explain: -25- DOJ-OGR-00010839
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Juror ID: 26
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-00010840
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Juror ID: 26
DECLARATION
I, Juror Number 26 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 4 day of November, 2021
DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER.
-27-
DOJ-OGR-00010841
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Juror ID: 26
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-00010842
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 90 of 353
Juror ID: 26
-29-
DOJ-OGR-00010843
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 91 of 353 Juror ID: 76 -30- DOJ-OGR-00010844
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 92 of 353
Juror ID: 26
-31-
DOJ-OGR-00010845
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 93 of 353
Juror ID: 29
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-00010846
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 94 of 353
Juror ID: 29
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. 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-00010847
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 95 of 353 Juror ID: 29 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-00010848
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 96 of 353 Juror ID: 29 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-00010849
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 97 of 353 Juror ID: 29 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-00010850
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 98 of 353 Juror ID: 29 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-00010851
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 99 of 353
Juror ID: 29
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-00010852
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 100 of 353
Juror ID: 29
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-00010853
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 101 of 353
Juror ID: 29
17a. If yes, please explain:
PRIOR JURY SERVICE
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-00010854
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 102 of 353 Juror ID: 29 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-00010855
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 103 of 353 Juror ID: 29 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-00010856
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 104 of 353 Juror ID: 29 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: My cousin was a law officer -14- DOJ-OGR-00010857
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 105 of 353 Juror ID: 29 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-00010858
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 106 of 353 Juror ID: 29 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: Bro wh-in-law works for 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-00010859
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 107 of 353
Juror ID: 29
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 the 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-00010860
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 108 of 353
Jour ID: 29
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:
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-18-
DOJ-OGR-00010861
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 109 of 353 Juror ID: 29 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 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 have heard of this case on TV, but I don't recall seeing or hearing about Ms. Maxwell, but I am not 100% sure. 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 If yes or unsure, please summarize your opinion: -19- DOJ-OGR-00010862
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 110 of 353 Juror ID: 29 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: I have heard of Mr. Epstein on CNN and perhaps on ABC/NBC, but not in great details. 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-00010863
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 111 of 353
Juror ID: 29
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-00010864
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 112 of 353
Juror ID: 29
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-00010865
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 113 of 353 Juror ID: 29 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-00010866
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 114 of 353 Juror ID: 29 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 If yes, please explain: 47a. 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-00010867
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 115 of 353
Juror ID: 29
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) 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 No
50a. If yes, please explain:
-25-
DOJ-OGR-00010868
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 116 of 353 Juror ID: 29 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-00010869
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 117 of 353 Juror ID: 29 DECLARATION I, Juror Number 29 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 04 day of November, 2021 DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER. 29 -27- DOJ-OGR-00010870
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 118 of 353 Juror ID: 29 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-00010871
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 119 of 353 Juror ID: 29 -29- DOJ-OGR-00010872
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 120 of 353 Juror ID: 29 -30- DOJ-OGR-00010873
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 121 of 353 Juror ID: 29 -31- DOJ-OGR-00010874
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 122 of 353
Juror ID: 37
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-00010875
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 123 of 353
Juror ID: 37
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. 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-00010876
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 124 of 353 Juror ID: 31 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-00010877
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 125 of 353 Juror ID: 37 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-00010878
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 126 of 353 Juror ID: 37 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-00010879
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 127 of 353 Juror ID: 37 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: 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-00010880
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 128 of 353 Juror ID: 37 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-00010881
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 129 of 353
Juror ID: 37
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-00010882
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 130 of 353 Juror ID: 3-7 17a. If yes, please explain: ____________________________________________________ ____________________________________________________ ____________________________________________________ ____________________________________________________ PRIOR JURY SERVICE 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-00010883
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 131 of 353 Juror ID: 37 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-00010884
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 132 of 353 Juror ID: 37 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 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 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 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 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-00010885
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 133 of 353
Juror ID: 37
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-00010886
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 134 of 353 Juror ID: 37 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-00010887
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 135 of 353 Juror ID: 37 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-00010888
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 136 of 353 Juror ID: 37 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 the 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-00010889
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 137 of 353
Juror ID: 37
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:
____________________________________________________________________________________
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-18-
DOJ-OGR-00010890
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 138 of 353 Juror ID: 37 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 remember hearing she was arrested on the news. 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-00010891
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 139 of 353
Juror ID: 37
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:
that he was assested and that he commited suicide on the news
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-00010892
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 140 of 353 Juror ID: 37 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-00010893
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 141 of 353 Juror ID: 37 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-00010894
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 142 of 353 Juror ID: 37 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-00010895
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 143 of 353 Juror ID: 37 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-00010896
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 144 of 353 Juror ID: 37 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) 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 No 50a. If yes, please explain: -25- DOJ-OGR-00010897
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 145 of 353 Juror ID: 37 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-00010898
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 146 of 353
Juror ID: 37
DECLARATION
I, Juror Number 31 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 4 day of November, 2021
DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER.
-27-
DOJ-OGR-00010899
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 147 of 353 Juror ID: 37 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-00010900
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 148 of 353 Juror ID: 37 -29- DOJ-OGR-00010901
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 149 of 353 Juror ID: 31 -30- DOJ-OGR-00010902
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 150 of 353 Juror ID: 37 -31- DOJ-OGR-00010903
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 151 of 353
Juror ID: 48
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.
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DOJ-OGR-00010904
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 152 of 353
Juror ID: 48
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. 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.
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DOJ-OGR-00010905
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Juror ID: 48
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.
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DOJ-OGR-00010906
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 154 of 353 Juror ID: 48 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-00010907
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 155 of 353 Juror ID: 48 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-00010908
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Juror ID: 48
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
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
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
If no, please explain:
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DOJ-OGR-00010909
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Juror ID: 48
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:
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DOJ-OGR-00010910
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Juror ID: 48
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
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DOJ-OGR-00010911
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 159 of 353 Juror ID: 48 17a. If yes, please explain:
PRIOR JURY SERVICE 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-00010912
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 160 of 353 Juror ID: 48 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-00010913
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Juror ID: 48
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
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DOJ-OGR-00010914
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 162 of 353 Juror ID: 48 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-00010915
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 163 of 353 Juror ID: 48 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-00010916
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Juror ID: 48
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
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DOJ-OGR-00010917
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Juror ID: 48
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 the 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? 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? 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? 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 No Alison Moe No Lara Pomerantz No Andrew Rohrbach No
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DOJ-OGR-00010918
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 166 of 353 Juror ID: 48 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-00010919
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 167 of 353 Juror ID: 48 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 remember that Ms. Maxwell was identified as a friend of Jeffrey Epstein and that she was charged with a crime involving him. I heard this on news broadcast, as well as reading an article in the newspaper. 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 No 35a. If yes or unsure, please summarize your opinion: -19- DOJ-OGR-00010920
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 168 of 353 Juror ID: 48 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 No 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 Yes 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. I heard that Mr Epstein was arrested on charges of sexual misconduct. I heard this on news broadcast as well as reading articles in the newspaper. 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 No 38a. If yes, when and where did you state or post your opinion? -20- DOJ-OGR-00010921
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 169 of 353 Juror ID: 48 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 No 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 No 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 Yes -21- DOJ-OGR-00010922
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 170 of 353 Juror ID: 48 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-00010923
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Juror ID: 48
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:
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DOJ-OGR-00010924
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 172 of 353 Juror ID: 48 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 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 If yes, without listing names, please explain: 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 If yes to 48b, please explain: -24- DOJ-OGR-00010925
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 173 of 353 Juror ID: 48 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) No If yes, without listing names, please explain: 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 If yes to 49b, please explain: 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 No If yes, please explain: -25- DOJ-OGR-00010926
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 174 of 353 Juror ID: 48 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-00010927
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 175 of 353 Juror ID: 48 DECLARATION I, Juror Number 48 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 4 day of November, 2021 DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER. Juror Number 48 -27- DOJ-OGR-00010928
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Juror ID: 48
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-00010929
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 177 of 353 Juror ID: 48 -29- DOJ-OGR-00010930
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 178 of 353 Juror ID: 48 -30- DOJ-OGR-00010931
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 179 of 353 Juror ID: 48 -31- DOJ-OGR-00010932
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 180 of 353
Juror ID: 49
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-00010933
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 181 of 353
Juror ID: 49
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. 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-00010934
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 182 of 353 Juror ID: 49 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-00010935
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 183 of 353 Juror ID: 149 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-00010936
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 184 of 353 Juror ID: 49 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-00010937
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 185 of 353 Juror ID: 49 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: 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-00010938
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 186 of 353 Juror ID: 49 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-00010939
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 187 of 353
Juror ID: 49
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-00010940
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 188 of 353 Juror ID: 49 17a. If yes, please explain: _____________________________________________________ _____________________________________________________ _____________________________________________________ _____________________________________________________ _____________________________________________________ PRIOR JURY SERVICE 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-00010941
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 189 of 353 Juror ID: 49 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-00010942
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 190 of 353 Juror ID: 49 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-00010943
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 191 of 353 Juror ID: 49 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-00010944
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 192 of 353 Juror ID: 49 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-00010945
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 193 of 353
Juror ID: 49
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-00010946
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 194 of 353
Juror ID: 49
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 the 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-00010947
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 195 of 353 Juror ID: 49 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-00010948
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 196 of 353 Juror ID: 49 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 heard it on the News TV 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-00010949
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 197 of 353 Juror ID: 119 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: I have heard it on the News TV 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-00010950
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 198 of 353 Juror ID: 49 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-00010951
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 199 of 353 Juror ID: 49 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-00010952
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 200 of 353 Juror ID: 49 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-00010953
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 201 of 353 Juror ID: 119 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-00010954
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 202 of 353 Juror ID: 49 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) No If yes, without listing names, please explain: 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 If yes to 49b, please explain: 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 No If yes, please explain: -25- DOJ-OGR-00010955
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 203 of 353 Juror ID: 49 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-00010956
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 204 of 353 Juror ID: 49 DECLARATION I, Juror Number 49 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 14 day of November, 2021 DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER. 49 -27- DOJ-OGR-00010957
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 205 of 353
Juror ID: 219
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-00010958
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 206 of 353 Juror ID: 149 -29- DOJ-OGR-00010959
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 207 of 353 Juror ID: 49 -30- DOJ-OGR-00010960
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 208 of 353 Juror ID: 49 -31- DOJ-OGR-00010961
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 209 of 353
Juror ID: 50
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-00010962
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 210 of 353
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. 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-00010963
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 211 of 353 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-00010964
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 212 of 353 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-00010965
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 213 of 353
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-00010966
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 214 of 353
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-00010967
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 215 of 353 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 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 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 If no, please explain: -9- DOJ-OGR-00010968
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 216 of 353 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-00010969
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 217 of 353 Juror ID: 50 17a. If yes, please explain: PRIOr JURY SERVICE 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-00010970
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 218 of 353 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-00010971
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 219 of 353
Juror ID: 50
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
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
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
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
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-00010972
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 220 of 353 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-00010973
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 221 of 353 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-00010974
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 222 of 353
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-00010975
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 223 of 353
Junior 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 the 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?
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?
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?
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-00010976
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 224 of 353 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 Pagliucca 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-00010977
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 225 of 353 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 girlfried - 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-00010978
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 226 of 353 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 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 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 If yes, when and where did you state or post your opinion? -20- DOJ-OGR-00010979
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 227 of 353 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 No 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 No 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 Yes -21- DOJ-OGR-00010980
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 228 of 353
Junior 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-00010981
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 229 of 353 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 43 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-00010982
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 230 of 353 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-00010983
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 231 of 353 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-00010984
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 232 of 353 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-00010985
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 233 of 353 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-00010986
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 234 of 353 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-00010987
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 235 of 353 Juror ID: 50 -29- DOJ-OGR-00010988
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 236 of 353 Juror ID: 50 -30- DOJ-OGR-00010989
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 237 of 353 Juror ID: 50 -31- DOJ-OGR-00010990
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 238 of 353
Juror ID: 70
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.
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DOJ-OGR-00010991
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Juror ID: 70
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. 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, her jury must find that the Government has proven each element of that crime beyond a reasonable doubt.
-4-
DOJ-OGR-00010992
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Juror ID: 70
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-00010993
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 241 of 353 Juror ID: 7ф 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-00010994
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 242 of 353 Juror ID: 70 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-00010995
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Juror ID: 70
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:
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DOJ-OGR-00010996
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Juror ID: 76
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-00010997
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Juror ID: 70
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-00010998
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 246 of 353 Juror ID: 70 17a. If yes, please explain: ____________________________________________________ ____________________________________________________ ____________________________________________________ PRI JURY SERVICE 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-00010999
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 247 of 353 Juror ID: 70 21a. If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case? N/A 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? N/A 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? N/A Yes No 23b. If yes to 23a, please explain: -12- DOJ-OGR-00011000
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 248 of 353 Juror ID: 74 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-00011001
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 249 of 353 Juror ID: 70 26a. If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case? N/A 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? N/A 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-00011002
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 250 of 353 Juror ID: 70 28b. If yes to 28, would this affect your ability to serve as a fair and impartial juror in this case? N/A 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? N/A 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-00011003
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 251 of 353 Juror ID: 70 30b. If yes to 30, would this affect your ability to serve as a fair and impartial juror in this case? Yes No N/A 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 N/A 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-00011004
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Junior ID: 74
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 the 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
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DOJ-OGR-00011005
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 253 of 353 Juror ID: 70 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-00011006
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 254 of 353 Juror ID: 70 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: Just news headlines around Epstein and her possibly being involved in his crimes, etc. 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-00011007
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Juror ID: 76
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:
That he had a party ring with high profile people, this would engage in a variety of illegal entertainment, usually outside the U.S.
I know he died in prison, but I don't remember if he had already been sentenced or if he died while awaiting a 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-00011008
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Juror ID: 70
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-00011009
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 257 of 353 Juror ID: 70 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-00011010
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Juror ID: 70
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 N/A
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-00011011
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 259 of 353 Juror ID: 70 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-00011012
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Juror ID: 70
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) 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 N/A
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 No
50a. If yes, please explain:
-25-
DOJ-OGR-00011013
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 261 of 353 Juror ID: 70 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-00011014
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 262 of 353 Juror ID: 70 DECLARATION I, Juror Number 70 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 12th day of November, 2021 DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER. # 70 -27- DOJ-OGR-00011015
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Juror ID: 70
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-00011016
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 264 of 353 Juror ID: 78 -29- DOJ-OGR-00011017
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 265 of 353 Junior ID: 70 -30- DOJ-OGR-00011018
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 266 of 353 Juror ID: 70 -31- DOJ-OGR-00011019
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 267 of 353
Juror ID: 89
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.
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DOJ-OGR-00011020
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 268 of 353
Juror ID: 89
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. 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-00011021
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 269 of 353 Juror ID: 89 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-00011022
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 270 of 353 Juror ID: 89 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-00011023
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 271 of 353 Juror ID: 89 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-00011024
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 272 of 353 Juror ID: 89 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-00011025
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 273 of 353 Juror ID: 89 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-00011026
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 274 of 353
Juror ID: 89
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-00011027
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 275 of 353 Junior ID: 89 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-00011028
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 276 of 353 Juror ID: 89 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-00011029
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 277 of 353 Juror ID: 89 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-00011030
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 278 of 353 Juror ID: 89 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-00011031
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 279 of 353 Juror ID: 89 28b. If yes to 28, would this affect your ability to serve as a fair and impartial juror in this case? Yes No 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 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 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 If yes, please explain: -15- DOJ-OGR-00011032
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 280 of 353 Juror ID: 89 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-00011033
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 281 of 353
Junior ID: 89
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 the 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
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DOJ-OGR-00011034
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 282 of 353 Juror ID: 89 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-00011035
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 283 of 353 Juror ID: 89 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 HAVE HEARD HER NAME BUT DO NOT know ANY DETAILS of THE CASE/CHARGES 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-00011036
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 284 of 353 Juror ID: 89 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: I HAVE HEARD THIS NAME IN THE NEWS AND I AM AWARE THAT HE COMMITTED SUICIDE WHILE IN JAIL. 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-00011037
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 285 of 353 Juror ID: 89 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-00011038
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 286 of 353 Junior ID: 89 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-00011039
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 287 of 353
Juror ID: 89
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-00011040
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 288 of 353 Juror ID: 89 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-00011041
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 289 of 353 Juror ID: 89 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) 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 No 50a. If yes, please explain: -25- DOJ-OGR-00011042
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 290 of 353 Juror ID: 89 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-00011043
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 291 of 353
Juror ID: 89
DECLARATION
I, Juror Number 89, 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 4 day of November, 2021
DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER.
-27-
DOJ-OGR-00011044
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 292 of 353 Juror ID: 39 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-00011045
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 293 of 353
Junior ID: 89
-29-
DOJ-OGR-00011046
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 294 of 353 Junior ID: 89 -30- DOJ-OGR-00011047
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 295 of 353 Juror ID: 89 -31- DOJ-OGR-00011048
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 296 of 353
Juror ID: 119
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-00011049
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 297 of 353
Juror ID: 119
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. 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-00011050
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 298 of 353 Juror ID: 119 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-00011051
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 299 of 353 Juror ID: 119 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-00011052
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 300 of 353 Juror ID: 119 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-00011053
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 301 of 353 Juror ID: 119 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: 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-00011054
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 302 of 353 Juror ID: 119 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-00011055
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 303 of 353 Juror ID: 119 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-00011056
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 304 of 353 Juror ID: 119 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 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-00011057
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 305 of 353 Juror ID: 119 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. 23a. 23b. -12- DOJ-OGR-00011058
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 306 of 353 Juror ID: 119 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 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 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 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 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-00011059
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 307 of 353 Juror ID: 119 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-00011060
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 308 of 353 Juror ID: 119 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-00011061
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 309 of 353 Juror ID: 119 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-00011062
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 310 of 353
Juror ID: 119
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 the 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
Allison Moe Yes No
Lara Pomerantz Yes No
Andrew Rohrbach Yes No
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DOJ-OGR-00011063
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 311 of 353
Juror ID: 119
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-00011064
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 312 of 353 Juror ID: 119 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: Ms. Maxwell's name was mentioned on a TV news program associated with Mr. Epstein. 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-00011065
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 313 of 353
Juror ID: ___________________________________
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:
I believe I heard Mr. Epstein's passing.
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-00011066
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 314 of 353 Juror ID: 119 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 No 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 No 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-00011067
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 315 of 353 Juror ID: 119 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-00011068
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 316 of 353
Juror ID: 119
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-00011069
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 317 of 353 Juror ID: 119 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. [Blacked out section] 48a. 48b. 48c. -24- DOJ-OGR-00011070
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 318 of 353 Juror ID: 119 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) No If yes, without listing names, please explain: 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 If yes to 49b, please explain: 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 No If yes, please explain: -25- DOJ-OGR-00011071
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 319 of 353 Juror ID: 119 51. CLOSING QUESTION -26- DOJ-OGR-00011072
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 320 of 353 Juror ID: 119 DECLARATION I, Juror Number 119 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 #119 DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER. -27- DOJ-OGR-00011073
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 321 of 353 Juror ID: 119 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-00011074
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 322 of 353 Juror ID: 119 -29- DOJ-OGR-00011075
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 323 of 353 Juror ID: 119 -30- DOJ-OGR-00011076
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 324 of 353 Juror ID: 119 -31- DOJ-OGR-00011077
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 325 of 353
Juror ID: 124
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 will 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-00011078
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 326 of 353
Juror ID: 124
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. 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.
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 327 of 353
Juror ID: 124
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.
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 328 of 353 Juror ID: 124 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-00011081
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 329 of 353 Juror ID: 124 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-00011082
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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:
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 331 of 353 Juror ID: 124 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 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 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 If no, please explain: -9- DOJ-OGR-00011084
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 332 of 353 Juror ID: 129 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-00011085
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17a. If yes, please explain:
PRIOR JURY SERVICE
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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 334 of 353 Juror ID: 129 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-00011087
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 335 of 353 Juror ID: 124 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 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 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 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 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-00011088
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 336 of 353 Juror ID: 129 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: Friends with occupations of: Attorney, Police officers, legal counsel, etc. -14- DOJ-OGR-00011089
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 337 of 353 Juror ID: 124 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-00011090
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 338 of 353 Juror ID: 124 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: Friends and family members that were for the agency 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-00011091
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 339 of 353 Juror ID: 124 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 the 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-00011092
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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:
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 341 of 353 Juror ID: 124 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: ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ 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-00011094
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 342 of 353 Juror ID: 124 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 No 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 Yes 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 news reporting all on the accusations on Mr. Epstein 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 No 38a. If yes, when and where did you state or post your opinion? -20- DOJ-OGR-00011095
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 343 of 353 Juror ID: 124 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 No 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 No 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 Yes -21- DOJ-OGR-00011096
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 344 of 353 Juror ID: 129 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-00011097
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Juror ID: 124
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:
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 346 of 353 Juror ID: 124 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 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 If yes, without listing names, please explain: Child molested by an adult 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 If yes to 48b, please explain: -24- DOJ-OGR-00011099
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 347 of 353 Juror ID: 109 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) No If yes, without listing names, please explain: 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 If yes to 49b, please explain: 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 No If yes, please explain: -25- DOJ-OGR-00011100
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 348 of 353 Juror ID: 124 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-00011101
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 349 of 353 Juror ID: 124 DECLARATION I, Juror Number 124 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 7th day of November, 2021 DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER. -27- DOJ-OGR-00011102
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 350 of 353
Junior ID: 124
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.
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 351 of 353 Juror ID: 124 -29- DOJ-OGR-00011104
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 353 of 353
Juror ID: 124
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Individual Pages
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 7 of 353 Juror ID: 2 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. 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-00010760
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Juror ID: 2
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.
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 9 of 353 Juror ID: 2 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-00010762
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 10 of 353 Juror ID: 2 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.: Definitely Not 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. Definitely Know 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: Doctor Excused -7- DOJ-OGR-00010763
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 11 of 353 Juror ID: 2 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-00010764
Page 12 of 353 - DOJ-OGR-00010765
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 12 of 353 Juror ID: 2 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-00010765
Page 13 - DOJ-OGR-00010766
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 13 of 353
Juror ID: 2
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
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DOJ-OGR-00010766
Page 14 of 353 - DOJ-OGR-00010767
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 14 of 353 Juror ID: 2 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-00010767
Page 15 of 353 - DOJ-OGR-00010768
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 15 of 353 Juror ID: 2 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-00010768
Page 16 - DOJ-OGR-00010769
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 16 of 353 Juror ID: 2 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-00010769
Page 17 - DOJ-OGR-00010770
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 17 of 353 Juror ID: 2 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-00010770
Page 18 of 353 - DOJ-OGR-00010771
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 18 of 353 Juror ID: 2 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-00010771
Page 19 - DOJ-OGR-00010772
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 19 of 353
Juror ID: 2
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
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DOJ-OGR-00010772
Page 20 of 353 - DOJ-OGR-00010773
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 20 of 353 Juror ID: 2 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 the 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-00010773
Page 21 - DOJ-OGR-00010774
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 21 of 353
Juror ID: 2
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:
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DOJ-OGR-00010774
Page 22 of 353 - DOJ-OGR-00010775
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 22 of 353 Juror ID: 2 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: Channel 2 news 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-00010775
Page 23 - DOJ-OGR-00010776
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 23 of 353
Juror ID: 2
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:
New York Evening News
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?
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DOJ-OGR-00010776
Page 24 - DOJ-OGR-00010777
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 24 of 353 Juror ID: 2 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-00010777
Page 25 of 353 - DOJ-OGR-00010778
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 25 of 353 Juror ID: 2 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-00010778
Page 26 of 353 - DOJ-OGR-00010779
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 26 of 353 Juror ID: 2 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-00010779
Page 27 - DOJ-OGR-00010780
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 27 of 353 Juror ID: 2 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-00010780
Page 28 - DOJ-OGR-00010781
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 28 of 353
Juror ID: 2
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) 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 No
50a. If yes, please explain:
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DOJ-OGR-00010781
Page 29 of 353 - DOJ-OGR-00010782
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 29 of 353 Juror ID: 2 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):
Page 30 of 353 - DOJ-OGR-00010783
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 30 of 353
Juror ID: 2
DECLARATION
I, Juror Number 2 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 2 day of November, 2021
DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER.
2
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DOJ-OGR-00010783
Page 31 - DOJ-OGR-00010784
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 31 of 353 Juror ID: 2 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-00010784
Page 32 - DOJ-OGR-00010785
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 32 of 353 Juror ID: 8 -29- DOJ-OGR-00010785
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 33 of 353 Juror ID: 2 -30- DOJ-OGR-00010786
Page 34 of 353 - DOJ-OGR-00010787
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 34 of 353 Juror ID: 2 -31- DOJ-OGR-00010787
Page 35 - DOJ-OGR-00010788
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 35 of 353
Juror ID: 7
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.
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DOJ-OGR-00010788
Page 36 of 353 - DOJ-OGR-00010789
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 36 of 353
Juror ID: 7
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. 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.
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DOJ-OGR-00010789
Page 37 - DOJ-OGR-00010790
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 37 of 353 Juror ID: 7 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-00010790
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 38 of 353 Juror ID: 7 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-00010791
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Juror ID: 1
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:
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 40 of 353 Juror ID: 7 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: 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-00010793
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Juror ID: 7
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:
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 42 of 353
Juror ID: 1
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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 43 of 353 Juror ID: 7 17a. If yes, please explain: ______________________________________ ______________________________________ ______________________________________ ______________________________________ PRIOR JURY SERVICE 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-00010796
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 44 of 353 Juror ID: 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-00010797
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 45 of 353
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:
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____________________________________________________
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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 46 of 353 Juror ID: 7 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: MOTHER ADMIN SUPERVISOR -14- DOJ-OGR-00010799
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 47 of 353 Juror ID: 7 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-00010800
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 48 of 353 Juror ID: 1 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: MOTHER ADMIN 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-00010801
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 49 of 353 Juror ID: 7 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 the 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-00010802
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 50 of 353
Juror ID: ___________________________________
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:
____________________________________________________________________________________
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____________________________________________________________________________________
____________________________________________________________________________________
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 51 of 353 Juror ID: 1 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: 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-00010804
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 52 of 353
Juror ID: 1
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:
HE PASSED AWAY IN PRISON
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?
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 53 of 353
Juror ID: ___________________________________
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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 54 of 353 Juror ID: 7 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-00010807
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Juror ID: 2
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:
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 56 of 353 Juror ID: 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-00010809
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 57 of 353 Juror ID: 1 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) No If yes, without listing names, please explain: 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 If yes to 49b, please explain: 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 No If yes, please explain: -25- DOJ-OGR-00010810
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 58 of 353 Juror ID: 1 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-00010811
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 59 of 353
Juror ID: 7
DECLARATION
I, Juror Number 7 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.
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 60 of 353 Juror ID: 1 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-00010813
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 61 of 353 Juror ID: 7 -29- DOJ-OGR-00010814
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 63 of 353 Juror ID: 1 -31- DOJ-OGR-00010816
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Juror ID: 26
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.
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Juror ID: 26
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. 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-00010818
Page 66 of 353 - DOJ-OGR-00010819
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Juror ID: 26
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-00010819
Page 67 - DOJ-OGR-00010820
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 67 of 353 Juror ID: 26 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-00010820
Page 68 of 353 - DOJ-OGR-00010821
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 68 of 353 Juror ID: 26 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-00010821
Page 69 of 353 - DOJ-OGR-00010822
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Jury ID: 26
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-00010822
Page 70 of 353 - DOJ-OGR-00010823
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Juror ID: 26
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-00010823
Page 71 - DOJ-OGR-00010824
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Juror ID: 26
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-00010824
Page 72 of 353 - DOJ-OGR-00010825
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Juror ID: 26
17a. If yes, please explain:
PRIOR JURY SERVICE
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-00010825
Page 73 of 353 - DOJ-OGR-00010826
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 73 of 353 Juror ID: 26 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-00010826
Page 74 of 353 - DOJ-OGR-00010827
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 74 of 353 Juror ID: 26 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-00010827
Page 75 of 353 - DOJ-OGR-00010828
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 75 of 353 Juror ID: 26 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: I work as an Admin. Contract Specialist. -14- DOJ-OGR-00010828
Page 76 of 353 - DOJ-OGR-00010829
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 76 of 353 Juror ID: 76 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-00010829
Page 77 of 353 - DOJ-OGR-00010830
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 77 of 353 Juror ID: 26 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: I work with Admin. Contract Specialist. 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-00010830
Page 78 of 353 - DOJ-OGR-00010831
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 78 of 353 Juror ID: 26 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 the 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-00010831
Page 79 - DOJ-OGR-00010832
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 79 of 353
Juror ID: 26
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:
____________________________________________________________________________________
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____________________________________________________________________________________
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____________________________________________________________________________________
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-18-
DOJ-OGR-00010832
Page 80 of 353 - DOJ-OGR-00010833
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 80 of 353 Juror ID: 26 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: ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________ 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-00010833
Page 81 of 353 - DOJ-OGR-00010834
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 81 of 353 Juror ID: 26 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: I saw on television media that Mr. Epstein was accused of sex trafficking. 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-00010834
Page 82 of 353 - DOJ-OGR-00010835
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 82 of 353 Juror ID: 26 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-00010835
Page 83 of 353 - DOJ-OGR-00010836
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 83 of 353 Juror ID: 24 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-00010836
Page 84 of 353 - DOJ-OGR-00010837
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 84 of 353 Juror ID: 26 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-00010837
Page 85 of 353 - DOJ-OGR-00010838
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 85 of 353 Juror ID: 26 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-00010838
Page 86 - DOJ-OGR-00010839
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 86 of 353 Juror ID: 20 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) No If yes, without listing names, please explain: 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 If yes to 49b, please explain: 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 No If yes, please explain: -25- DOJ-OGR-00010839
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Juror ID: 26
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-00010840
Page 88 of 353 - DOJ-OGR-00010841
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 88 of 353
Juror ID: 26
DECLARATION
I, Juror Number 26 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 4 day of November, 2021
DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER.
-27-
DOJ-OGR-00010841
Page 89 - DOJ-OGR-00010842
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 89 of 353
Juror ID: 26
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-00010842
Page 90 of 353 - DOJ-OGR-00010843
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Juror ID: 26
-29-
DOJ-OGR-00010843
Page 91 - DOJ-OGR-00010844
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 91 of 353 Juror ID: 76 -30- DOJ-OGR-00010844
Page 92 - DOJ-OGR-00010845
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Juror ID: 26
-31-
DOJ-OGR-00010845
Page 93 - DOJ-OGR-00010846
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 93 of 353
Juror ID: 29
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-00010846
Page 94 of 353 - DOJ-OGR-00010847
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 94 of 353
Juror ID: 29
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. 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.
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 95 of 353 Juror ID: 29 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-00010848
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 96 of 353 Juror ID: 29 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-00010849
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 97 of 353 Juror ID: 29 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-00010850
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 98 of 353 Juror ID: 29 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-00010851
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Juror ID: 29
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:
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Juror ID: 29
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
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Juror ID: 29
17a. If yes, please explain:
PRIOR JURY SERVICE
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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 102 of 353 Juror ID: 29 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-00010855
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 103 of 353 Juror ID: 29 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-00010856
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 104 of 353 Juror ID: 29 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: My cousin was a law officer -14- DOJ-OGR-00010857
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 105 of 353 Juror ID: 29 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-00010858
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 106 of 353 Juror ID: 29 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: Bro wh-in-law works for 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-00010859
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Juror ID: 29
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 the 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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 108 of 353
Jour ID: 29
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:
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 109 of 353 Juror ID: 29 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 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 have heard of this case on TV, but I don't recall seeing or hearing about Ms. Maxwell, but I am not 100% sure. 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 If yes or unsure, please summarize your opinion: -19- DOJ-OGR-00010862
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 110 of 353 Juror ID: 29 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: I have heard of Mr. Epstein on CNN and perhaps on ABC/NBC, but not in great details. 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-00010863
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Juror ID: 29
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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 112 of 353
Juror ID: 29
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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 113 of 353 Juror ID: 29 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-00010866
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 114 of 353 Juror ID: 29 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 If yes, please explain: 47a. 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-00010867
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Juror ID: 29
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) 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 No
50a. If yes, please explain:
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 116 of 353 Juror ID: 29 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-00010869
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 117 of 353 Juror ID: 29 DECLARATION I, Juror Number 29 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 04 day of November, 2021 DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER. 29 -27- DOJ-OGR-00010870
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 118 of 353 Juror ID: 29 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-00010871
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Juror ID: 37
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.
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Juror ID: 37
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. 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.
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Page 124 of 353 - DOJ-OGR-00010877
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 124 of 353 Juror ID: 31 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-00010877
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 125 of 353 Juror ID: 37 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-00010878
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 126 of 353 Juror ID: 37 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-00010879
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 127 of 353 Juror ID: 37 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: 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-00010880
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 128 of 353 Juror ID: 37 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-00010881
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Juror ID: 37
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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 130 of 353 Juror ID: 3-7 17a. If yes, please explain: ____________________________________________________ ____________________________________________________ ____________________________________________________ ____________________________________________________ PRIOR JURY SERVICE 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-00010883
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 131 of 353 Juror ID: 37 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-00010884
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 132 of 353 Juror ID: 37 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 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 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 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 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-00010885
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 133 of 353
Juror ID: 37
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:
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 134 of 353 Juror ID: 37 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-00010887
Page 135 of 353 - DOJ-OGR-00010888
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 135 of 353 Juror ID: 37 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-00010888
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 136 of 353 Juror ID: 37 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 the 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-00010889
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 137 of 353
Juror ID: 37
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:
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
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DOJ-OGR-00010890
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 138 of 353 Juror ID: 37 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 remember hearing she was arrested on the news. 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-00010891
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 139 of 353
Juror ID: 37
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:
that he was assested and that he commited suicide on the news
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?
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DOJ-OGR-00010892
Page 140 - DOJ-OGR-00010893
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 140 of 353 Juror ID: 37 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-00010893
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 141 of 353 Juror ID: 37 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-00010894
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 142 of 353 Juror ID: 37 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-00010895
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 143 of 353 Juror ID: 37 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-00010896
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 144 of 353 Juror ID: 37 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) 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 No 50a. If yes, please explain: -25- DOJ-OGR-00010897
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 145 of 353 Juror ID: 37 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-00010898
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 146 of 353
Juror ID: 37
DECLARATION
I, Juror Number 31 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 4 day of November, 2021
DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER.
-27-
DOJ-OGR-00010899
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 147 of 353 Juror ID: 37 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-00010900
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 148 of 353 Juror ID: 37 -29- DOJ-OGR-00010901
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 149 of 353 Juror ID: 31 -30- DOJ-OGR-00010902
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 150 of 353 Juror ID: 37 -31- DOJ-OGR-00010903
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 151 of 353
Juror ID: 48
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.
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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. 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.
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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.
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 154 of 353 Juror ID: 48 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-00010907
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 155 of 353 Juror ID: 48 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-00010908
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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
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
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
If no, please explain:
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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:
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Juror ID: 48
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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 159 of 353 Juror ID: 48 17a. If yes, please explain:
PRIOR JURY SERVICE 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-00010912
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 160 of 353 Juror ID: 48 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-00010913
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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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 162 of 353 Juror ID: 48 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-00010915
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 163 of 353 Juror ID: 48 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-00010916
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Juror ID: 48
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
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Juror ID: 48
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 the 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? 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? 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? 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 No Alison Moe No Lara Pomerantz No Andrew Rohrbach No
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 166 of 353 Juror ID: 48 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-00010919
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 167 of 353 Juror ID: 48 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 remember that Ms. Maxwell was identified as a friend of Jeffrey Epstein and that she was charged with a crime involving him. I heard this on news broadcast, as well as reading an article in the newspaper. 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 No 35a. If yes or unsure, please summarize your opinion: -19- DOJ-OGR-00010920
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 168 of 353 Juror ID: 48 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 No 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 Yes 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. I heard that Mr Epstein was arrested on charges of sexual misconduct. I heard this on news broadcast as well as reading articles in the newspaper. 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 No 38a. If yes, when and where did you state or post your opinion? -20- DOJ-OGR-00010921
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 169 of 353 Juror ID: 48 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 No 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 No 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 Yes -21- DOJ-OGR-00010922
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 170 of 353 Juror ID: 48 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-00010923
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Juror ID: 48
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:
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 172 of 353 Juror ID: 48 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 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 If yes, without listing names, please explain: 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 If yes to 48b, please explain: -24- DOJ-OGR-00010925
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 173 of 353 Juror ID: 48 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) No If yes, without listing names, please explain: 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 If yes to 49b, please explain: 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 No If yes, please explain: -25- DOJ-OGR-00010926
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 174 of 353 Juror ID: 48 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-00010927
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 175 of 353 Juror ID: 48 DECLARATION I, Juror Number 48 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 4 day of November, 2021 DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER. Juror Number 48 -27- DOJ-OGR-00010928
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Juror ID: 48
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.
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 177 of 353 Juror ID: 48 -29- DOJ-OGR-00010930
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 179 of 353 Juror ID: 48 -31- DOJ-OGR-00010932
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Juror ID: 49
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.
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 181 of 353
Juror ID: 49
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. 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.
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DOJ-OGR-00010934
Page 182 of 353 - DOJ-OGR-00010935
Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 182 of 353 Juror ID: 49 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-00010935
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 183 of 353 Juror ID: 149 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-00010936
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 184 of 353 Juror ID: 49 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-00010937
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 185 of 353 Juror ID: 49 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: 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-00010938
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 186 of 353 Juror ID: 49 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-00010939
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 187 of 353
Juror ID: 49
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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 188 of 353 Juror ID: 49 17a. If yes, please explain: _____________________________________________________ _____________________________________________________ _____________________________________________________ _____________________________________________________ _____________________________________________________ PRIOR JURY SERVICE 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-00010941
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 189 of 353 Juror ID: 49 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-00010942
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 190 of 353 Juror ID: 49 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-00010943
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 191 of 353 Juror ID: 49 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-00010944
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 192 of 353 Juror ID: 49 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-00010945
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 193 of 353
Juror ID: 49
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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 194 of 353
Juror ID: 49
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 the 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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 195 of 353 Juror ID: 49 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-00010948
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 196 of 353 Juror ID: 49 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 heard it on the News TV 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-00010949
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 197 of 353 Juror ID: 119 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: I have heard it on the News TV 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-00010950
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 198 of 353 Juror ID: 49 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-00010951
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 199 of 353 Juror ID: 49 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-00010952
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 200 of 353 Juror ID: 49 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-00010953
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 201 of 353 Juror ID: 119 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-00010954
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 202 of 353 Juror ID: 49 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) No If yes, without listing names, please explain: 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 If yes to 49b, please explain: 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 No If yes, please explain: -25- DOJ-OGR-00010955
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 203 of 353 Juror ID: 49 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-00010956
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 204 of 353 Juror ID: 49 DECLARATION I, Juror Number 49 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 14 day of November, 2021 DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER. 49 -27- DOJ-OGR-00010957
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 205 of 353
Juror ID: 219
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.
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DOJ-OGR-00010958
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 206 of 353 Juror ID: 149 -29- DOJ-OGR-00010959
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 207 of 353 Juror ID: 49 -30- DOJ-OGR-00010960
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 208 of 353 Juror ID: 49 -31- DOJ-OGR-00010961
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 209 of 353
Juror ID: 50
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.
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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. 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.
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 211 of 353 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-00010964
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 212 of 353 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-00010965
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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:
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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:
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 215 of 353 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 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 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 If no, please explain: -9- DOJ-OGR-00010968
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 216 of 353 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-00010969
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 217 of 353 Juror ID: 50 17a. If yes, please explain: PRIOr JURY SERVICE 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-00010970
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 218 of 353 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-00010971
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Juror ID: 50
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
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
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
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
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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 220 of 353 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-00010973
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 221 of 353 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-00010974
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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
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Junior 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 the 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?
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?
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?
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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 224 of 353 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 Pagliucca 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-00010977
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 225 of 353 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 girlfried - 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-00010978
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 226 of 353 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 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 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 If yes, when and where did you state or post your opinion? -20- DOJ-OGR-00010979
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 227 of 353 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 No 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 No 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 Yes -21- DOJ-OGR-00010980
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Junior 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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 229 of 353 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 43 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-00010982
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 230 of 353 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-00010983
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 231 of 353 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-00010984
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 232 of 353 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-00010985
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 233 of 353 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-00010986
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 234 of 353 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-00010987
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 237 of 353 Juror ID: 50 -31- DOJ-OGR-00010990
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Juror ID: 70
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.
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Juror ID: 70
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. 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, her jury must find that the Government has proven each element of that crime beyond a reasonable doubt.
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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.
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 241 of 353 Juror ID: 7ф 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-00010994
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 242 of 353 Juror ID: 70 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-00010995
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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:
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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:
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Juror ID: 70
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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 246 of 353 Juror ID: 70 17a. If yes, please explain: ____________________________________________________ ____________________________________________________ ____________________________________________________ PRI JURY SERVICE 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-00010999
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 247 of 353 Juror ID: 70 21a. If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case? N/A 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? N/A 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? N/A Yes No 23b. If yes to 23a, please explain: -12- DOJ-OGR-00011000
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 248 of 353 Juror ID: 74 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-00011001
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 249 of 353 Juror ID: 70 26a. If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case? N/A 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? N/A 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-00011002
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 250 of 353 Juror ID: 70 28b. If yes to 28, would this affect your ability to serve as a fair and impartial juror in this case? N/A 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? N/A 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-00011003
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 251 of 353 Juror ID: 70 30b. If yes to 30, would this affect your ability to serve as a fair and impartial juror in this case? Yes No N/A 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 N/A 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-00011004
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Junior ID: 74
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 the 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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 253 of 353 Juror ID: 70 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-00011006
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 254 of 353 Juror ID: 70 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: Just news headlines around Epstein and her possibly being involved in his crimes, etc. 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-00011007
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Juror ID: 76
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:
That he had a party ring with high profile people, this would engage in a variety of illegal entertainment, usually outside the U.S.
I know he died in prison, but I don't remember if he had already been sentenced or if he died while awaiting a 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?
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Juror ID: 70
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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 257 of 353 Juror ID: 70 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-00011010
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Juror ID: 70
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 N/A
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:
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 259 of 353 Juror ID: 70 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-00011012
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Juror ID: 70
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) 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 N/A
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 No
50a. If yes, please explain:
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 261 of 353 Juror ID: 70 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-00011014
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 262 of 353 Juror ID: 70 DECLARATION I, Juror Number 70 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 12th day of November, 2021 DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER. # 70 -27- DOJ-OGR-00011015
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Juror ID: 70
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.
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 264 of 353 Juror ID: 78 -29- DOJ-OGR-00011017
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Juror ID: 89
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.
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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. 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.
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 269 of 353 Juror ID: 89 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-00011022
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 270 of 353 Juror ID: 89 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-00011023
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 271 of 353 Juror ID: 89 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-00011024
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 272 of 353 Juror ID: 89 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-00011025
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 273 of 353 Juror ID: 89 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-00011026
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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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 275 of 353 Junior ID: 89 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-00011028
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 276 of 353 Juror ID: 89 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-00011029
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 277 of 353 Juror ID: 89 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-00011030
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 278 of 353 Juror ID: 89 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-00011031
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 279 of 353 Juror ID: 89 28b. If yes to 28, would this affect your ability to serve as a fair and impartial juror in this case? Yes No 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 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 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 If yes, please explain: -15- DOJ-OGR-00011032
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 280 of 353 Juror ID: 89 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-00011033
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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 the 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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 282 of 353 Juror ID: 89 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-00011035
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 283 of 353 Juror ID: 89 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 HAVE HEARD HER NAME BUT DO NOT know ANY DETAILS of THE CASE/CHARGES 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-00011036
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 284 of 353 Juror ID: 89 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: I HAVE HEARD THIS NAME IN THE NEWS AND I AM AWARE THAT HE COMMITTED SUICIDE WHILE IN JAIL. 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-00011037
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 285 of 353 Juror ID: 89 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-00011038
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 286 of 353 Junior ID: 89 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-00011039
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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:
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 288 of 353 Juror ID: 89 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-00011041
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 289 of 353 Juror ID: 89 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) 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 No 50a. If yes, please explain: -25- DOJ-OGR-00011042
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 290 of 353 Juror ID: 89 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-00011043
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Juror ID: 89
DECLARATION
I, Juror Number 89, 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 4 day of November, 2021
DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER.
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 292 of 353 Juror ID: 39 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-00011045
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Junior ID: 89
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Juror ID: 119
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.
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DOJ-OGR-00011049
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 297 of 353
Juror ID: 119
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. 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.
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DOJ-OGR-00011050
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 298 of 353 Juror ID: 119 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-00011051
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 299 of 353 Juror ID: 119 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-00011052
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 300 of 353 Juror ID: 119 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-00011053
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 301 of 353 Juror ID: 119 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: 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-00011054
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 302 of 353 Juror ID: 119 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-00011055
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 303 of 353 Juror ID: 119 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-00011056
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 304 of 353 Juror ID: 119 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 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-00011057
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 305 of 353 Juror ID: 119 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. 23a. 23b. -12- DOJ-OGR-00011058
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 306 of 353 Juror ID: 119 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 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 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 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 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-00011059
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 307 of 353 Juror ID: 119 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-00011060
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 308 of 353 Juror ID: 119 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-00011061
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 309 of 353 Juror ID: 119 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-00011062
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Juror ID: 119
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 the 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
Allison Moe Yes No
Lara Pomerantz Yes No
Andrew Rohrbach Yes No
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DOJ-OGR-00011063
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 311 of 353
Juror ID: 119
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:
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DOJ-OGR-00011064
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 312 of 353 Juror ID: 119 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: Ms. Maxwell's name was mentioned on a TV news program associated with Mr. Epstein. 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-00011065
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 313 of 353
Juror ID: ___________________________________
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:
I believe I heard Mr. Epstein's passing.
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?
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DOJ-OGR-00011066
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 314 of 353 Juror ID: 119 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 No 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 No 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-00011067
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 315 of 353 Juror ID: 119 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-00011068
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Juror ID: 119
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:
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DOJ-OGR-00011069
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 317 of 353 Juror ID: 119 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. [Blacked out section] 48a. 48b. 48c. -24- DOJ-OGR-00011070
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 318 of 353 Juror ID: 119 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) No If yes, without listing names, please explain: 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 If yes to 49b, please explain: 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 No If yes, please explain: -25- DOJ-OGR-00011071
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 319 of 353 Juror ID: 119 51. CLOSING QUESTION -26- DOJ-OGR-00011072
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 320 of 353 Juror ID: 119 DECLARATION I, Juror Number 119 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 #119 DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER. -27- DOJ-OGR-00011073
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 321 of 353 Juror ID: 119 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-00011074
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 322 of 353 Juror ID: 119 -29- DOJ-OGR-00011075
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 325 of 353
Juror ID: 124
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 will 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.
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Juror ID: 124
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. 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.
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Juror ID: 124
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.
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 328 of 353 Juror ID: 124 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-00011081
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 329 of 353 Juror ID: 124 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-00011082
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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:
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 331 of 353 Juror ID: 124 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 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 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 If no, please explain: -9- DOJ-OGR-00011084
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 332 of 353 Juror ID: 129 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-00011085
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Juror ID: 129
17a. If yes, please explain:
PRIOR JURY SERVICE
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
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 334 of 353 Juror ID: 129 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-00011087
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 335 of 353 Juror ID: 124 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 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 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 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 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-00011088
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 336 of 353 Juror ID: 129 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: Friends with occupations of: Attorney, Police officers, legal counsel, etc. -14- DOJ-OGR-00011089
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 337 of 353 Juror ID: 124 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-00011090
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 338 of 353 Juror ID: 124 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: Friends and family members that were for the agency 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-00011091
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 339 of 353 Juror ID: 124 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 the 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-00011092
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Juror ID: 124
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:
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 341 of 353 Juror ID: 124 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: ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ 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-00011094
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 342 of 353 Juror ID: 124 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 No 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 Yes 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 news reporting all on the accusations on Mr. Epstein 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 No 38a. If yes, when and where did you state or post your opinion? -20- DOJ-OGR-00011095
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 343 of 353 Juror ID: 124 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 No 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 No 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 Yes -21- DOJ-OGR-00011096
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 344 of 353 Juror ID: 129 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-00011097
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Juror ID: 124
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:
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 346 of 353 Juror ID: 124 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 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 If yes, without listing names, please explain: Child molested by an adult 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 If yes to 48b, please explain: -24- DOJ-OGR-00011099
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 347 of 353 Juror ID: 109 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) No If yes, without listing names, please explain: 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 If yes to 49b, please explain: 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 No If yes, please explain: -25- DOJ-OGR-00011100
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 348 of 353 Juror ID: 124 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-00011101
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 349 of 353 Juror ID: 124 DECLARATION I, Juror Number 124 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 7th day of November, 2021 DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER. -27- DOJ-OGR-00011102
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 350 of 353
Junior ID: 124
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.
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 351 of 353 Juror ID: 124 -29- DOJ-OGR-00011104
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Case 1:20-cr-00330-PAE Document 688 Filed 06/29/22 Page 352 of 353 Juror ID: 124 -30- DOJ-OGR-00011105
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Juror ID: 124
-31-
DOJ-OGR-00011106