Jury questionnaire with preliminary instructions in United States v. Maxwell, Nov. 2021

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X¶

UNTIED STATES OF AMERICA¶

GHISLAINE MAXWELL,¶

Defendant.¶

X¶

PRELIMINARY INSTRUCTIONS¶

20 Cr. 330 (MN)¶

JURY OUESTIONNAIRE¶

Please read the following instniction. carefully before completing any portion of this qtte.tiiiiinaire Plea< print pour juror initithcr in the space provided at the top of each page. Do ‘lease 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 arc no “right” or “wrong” answers, only truthfulanswers. 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¶

WOnneinented MID DEFENDANT OWEC710N: An disansof below. the Mosta Miens that baetsround Sefton:Son on awl “HUI timid be Inclatkd on this quodonnairt. a* the (lovernowni propo.ol lo do in the n,ilwa quelaionnaire in each or the asrA wan higbpeofile Ent (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. 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 counsel, you may indicate that on one of the blank pages at the end of this form. (Please identify the specificanswer or answers that you believe should remain confidential.) After a jury has been selected, all copies of your responses to the questionnaire will be returned to the Court.¶

SUMMARY OF THE CASE¶

The Court is selecting a jury for a trial commencing on Monday. November 29, 2021. Although it is never passible to predict the length of a trial, currently this trial is expected to last approximately I ] 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 chargesreferred 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.¶

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Ms. Maxwell has pled not guilty to all charges. Ms. Maxwell is presumed innocent, and before she can be found guilty on any charge, the jury must find that the Government has proven each element of that crime beyond a reasonable doubt.¶

(Please turn the page and read and complete the questionnaire.)¶

PLEASE ANSWER THE FOLLOWING QUESTIONS:¶

Juror ID: _____¶

BACKGROUND¶

Name: _____¶

Title Dr. Mr. Mr. Miss¶

Age: _____¶

Sex/Cender Identify: _____¶

Your place of birth: _____¶

Residence: County, City/Town, Neighborhood _____¶

How long have you lived in that area? _____¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your marital status? Single Married Separated Divorced Widowed¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

What is your current job status? (please check) Employed full-time Employed part-time Self-employed Homemaker¶

Live with domestic partner/s¶

Do (did) you supervise other people? O Yes 0 No¶

Please briefly describe what your management and/or supervisory responsibilities have entailed:¶

If you have held any other occupations in the past five years. please identify them here:¶

What is the highest level of education you have completed?¶

O Less than high school 0 High school graduate 0 Some college/vocational training¶

❑ College graduate. If so. please indicate degree and/or field of study:¶

❑ Post-graduate degree. If so, please indicate degree and/or field of study:¶

Please list all educational institutions you have attended, beginning with high school:¶

Please complete the following questions regarding your present spouse or domestic partner/significant other. If you arc divorced, widowed. or separated. please answer the following questions regarding your former spouse. partner or significant other’s employment:¶

What is his or her current employment status?¶

O Employed full-time ❑ Employed part-time 0 Self-employed 0 Homemaker¶

• Unemployed/laid-off ❑ Disabled ❑ Retired¶

O Full-time student (please state area of study)¶

O Other (please describe)¶

What is his or her occupation (or what was it. if he or she is no longer employed)?¶

By whom is (was) he or she employed?¶

How long has (did) he or she work there?¶

What arc (were) his or her specific duties at the job?¶

Does he or she supervise other people? ❑ Yes ❑ No¶

Do you have any children, including stepchildren? ❑ Yes ❑ No¶

If YES. please list the following for each: (Please include children you are currently raising or have ever raised even if they are not your biological children.)¶

Gender Age	Child Living
	Highest Level of Education Occupation/School Level

What are your hobbies, major interests, recreational pastimes and spare time activities and sports?¶

What are your spouse/domestic panner/significant other’s hobbies, major interests, recreational pastimes and spare time activities and spoils’?¶

Please list any groups and/or organizations to which you belong (for example. religious groups. professional organizations, volunteer activities, victim’s rights groups, etc.):¶

If you have ever been a published or unpublished author, please describe the things you have written and when you wrote them:¶

When in a group trying to make a decision, do you usually:¶

• Strongly express your views to get the outcome you believe is best
• Participate in the discussion and try to help build a consensus
• Listen and follow what you think the majority favors
• Other (please describe) _____

Do you have any strong views regarding people who are wealthy? Yes No¶

If Yes, please explain: _____¶

Commented [A6]: GOVERNMENT OBJECTION: The Government objects to this question on the grounds that it is vague, and will not provide a basis for a for-cause challenge.¶

Do you have any strong views regarding people who have luxurious lifestyles? Yes No¶

Commented [A7]: GOVERNMENT OBJECTION: The Government objects to these questions as vague and duplicative, and not framed in a way that would provide a basis for a for-cause challenge.¶

Commented [A8]: The parties will submit a joint letter to the Court on October 12, 2021 providing an estimate of the trial length.¶

Potential jurors will be called back for further questioning and jury selection from Tuesday, November 16, 2021 through Friday, November 19, 2021. The trial will commence on Monday, November 29, 2021. Generally, trial will be held five days per week, Monday through Friday, from 9:30 a.m. until 5:00 p.m. The Court will not sit on federal holidays, including on Christmas Day (Friday, December 24, 2021). The trial is expected to last about 11 weeks.¶

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.¶

Do any circumstances exist such that serving on the jury in this case would entail serious hardship or extreme inconvenience ?	Yes No
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	for placement on another panel for another case.
2.	Do you have any personal commitments that would make it difficult for you to get to court
	a Yes oNo
3.	Do you have any difficulty reading, speaking, or understanding English?
	a Yes oNo
4.	Do you have any medical. physical, or mental condition or illness that makes you unable to
	a Yes oNo
5.	Are you taking any medication which would prevent you from giving full attention to all the
	o Yes o No

6. Do you have any pre-paid travel plans between November 29, 2021 and January 15, 2022? Yes No	If yes, please describe your plans and the dates of travel (without indicating the name of where you work or the names of any family members or friends, or other personal information that might identify who you are):
Do you have any holiday plans for the period December 24th through January 3rdth? Yes No
7. Do you have any appointments during the next [ ] weeks that cannot be changed? Yes No
If yes, please explain: _____
Have you received a vaccine for COVID-19? Yes No If Yes, when did you receive the vaccine? _____
In light of the COVID-19 pandemic, do you have concerns about your ability to concentrate at trial, consider all the evidence, and make a conscientious decision in deliberation? Yes No
If yes, would courtroom precautions (ex. the use of air filters, use of a larger courtroom) alleviate your concerns?
Is there any reason relating to the COVID-19 pandemic that would make jury service an undue hardship for you or anyone in your household? No
If yes, please explain. _____ Is there anything else going on in your life or work that would prevent you from giving this case your full attention for the duration of trial? Yes No If yes, please explain. _____

8. Do you or does any member of your family or a close friend personally know or have past or
o Yes	a No
o Yes	a No
c. The U.S. Attorney for the Southern District of New York. Damian	or
o Yes	a No
Maurene Comey	❑ Yes o No
Alison Moe	o Yes ❑ No
Lara Pomerantz	o Yes a No
Andrew Rohrbach	o Yes o No
Christian Everdell of	& Gresser LLP o Yes o No
Jeffrey Pagliuca of Haddon.	and P.C. a Yes o No
Laura Menninger of Haddon.	and P.C. o Yes o No
Bobbi Stemheim of Law Offices of Bobbi C. Stemheim o Yes	o No
I The United States District Court Judge who is presiding over this case. Alison J.

CHARGES AND INDIVIDUALS INVOLVED
The indictment alleges that Ghislaine Maxwell conspired with Jeffrey Epstein and did entice minor females to travel to engage in illegal sex acts, transported a minor female to engage in criminal sexual activity, and engaged in sex trafficking of a minor. The indictment is not evidence; it is a formal way of charging a person with a crime in order to bring her to trial. Ms. Maxwell has pleaded not guilty. She is presumed innocent. Unless the government proves that she is guilty of these charges beyond a reasonable doubt, the jury must return a verdict of not guilty.
Would the fact that Ms. Maxwell faces a number of charges lead you to believe that she must be guilty of something? Yes No
If yes, please explain:
Please indicate if you ever had any connection with any of the following? Palm Beach County (Florida) Police Department Yes      No Federal Bureau of Investigations Yes      No U.S. Attorney’s Office - Southern District of Florida Yes      No U.S. Attorney’s Office- Southern District of New York Yes      No U.S. Department of Justice Yes      No		Palm Beach County (Florida) Police Department	Yes No	Federal Bureau of Investigations	Yes No	U.S. Attorney’s Office - Southern District of Florida	Yes No	U.S. Attorney’s Office- Southern District of New York	Yes No	U.S. Department of Justice	Yes No
Palm Beach County (Florida) Police Department	Yes No
Federal Bureau of Investigations	Yes No
U.S. Attorney’s Office - Southern District of Florida	Yes No
U.S. Attorney’s Office- Southern District of New York	Yes No
U.S. Department of Justice	Yes No
If you indicated Yes, please explain your connection:
EXPERIENCE WITH LEGAL SYSTEM
Have you ever served as a juror at trial or in a grand jury? Yes      No If yes, how many times? _____

Commented [A13]: GOVERNMENT OBJECTION: The Government objects to the “Charges & Individuals Involved” section proposed by the defendant on the grounds that it is duplicative of the questions proposed by the Government. In particular, the first question is duplicative of questions above and is argumentative and inappropriate.¶

Commented [A14R13]: DEFENDANT RESPONSE: The Government has not identified which questions they believe are duplicative. The first question, pertaining to the number of charges, does not appear to be duplicated in any Government-proposed question.¶

The Second Circuit has specifically approved discussion of the presumption of innocence in jury selection. See United States v. Velez-Vasquez, 116 F.3d 58, 61 (2d Cir. 1997) (upholding conviction where judge forgot to instruct on presumption of innocence in closing instructions where the concept had been discussed during voir dire).¶

Commented [A15]: GOVERNMENT OBJECTION: The Government objects to any references to the Southern District of Florida at this trial. The U.S. Attorney’s Office for the Southern District of Florida is not prosecuting this case. As the Government will address in a motion in limine, references to the USAO-SDFL are not appropriate at this trial.¶

Commented [A16]: GOVERNMENT OBJECTION: The Government does not believe the questions in the “Experience with Legal System” section should be included in the written questionnaire, because these questions will not reveal any bias or otherwise provide a basis for a for-cause challenge. Rather, the Government submits that such questions should be asked during the oral voir dire.¶

Commented [A17R16]: DEFENDANT RESPONSE: The defense believes that asking these questions on the questionnaire will save substantial amount of time and will allow the Court (and potentially parties) to follow up at the time of voir dire. Access to the information ahead of the voir dire will allow the Court to prepare to ask individual questions as necessary, some of which may best be asked outside the presence of other jurors (for example a prospective juror who previously had a negative experience as a juror).¶

Did you serve as a juror in state or federal cowl? 0 Yes		❑ No
Were you ever the foreperson of the jury?		❑ Yes ❑ No
Criminal or Civil		Type of case
		❑ Yes ❑ No
		O Yes 0 No
		❑ Yes ❑ No
		O Yes 0 No
		❑ Yes ❑ NO
impartial juror in this case?		❑ Yes ❑ No
O Yes	0 No	If Ycs, please explain:
O Ycs	0 No	If Ycs, please explain:
O Ycs	0 No	If Yes, please explain:
O Yes	0 No	If Yes, please explain and provide area of expertise:

Have you ever filed a criminal complaint? Yes No If Yes, please explain: _____
Have you ever contacted any prosecutor office: State District Attorney, United States Attorney’s Office, State Attorney General? Yes No If Yes, please explain the reason?
Have you ever reported someone for wrongdoing to your employer or a government agency? Yes No If Yes, please explain: _____
Other than for a minor traffic citation, have you ever been arrested for, charged with, or convicted of a crime? Yes No If Yes, please explain: _____
MEDIA ISSUES
How much do you rely on the following sources for your news? A lot Somewhat Not much Not at all Newspapers: Social Media: Television: Radio: Internet: Conversations: Other: _____		A lot	Somewhat	Not much	Not at all	Newspapers:				Social Media:				Television:				Radio:				Internet:				Conversations:				Other: _____
A lot	Somewhat	Not much	Not at all
Newspapers:
Social Media:
Television:
Radio:
Internet:
Conversations:
Other: _____
How often do you use or access those sources: Daily Occasionally Rarely

Commented [A18]: GOVERNMENT OBJECTION: The Government objects to the “Media Issues” section proposed by the defendant on the grounds that it is not streamlined in accordance with the Court’s Order. The Government submits that its proposed questions ask the jurors what is necessary on the subject but is not as unduly burdensome as the defendant’s proposal. Many of the questions are vague, confusing, and argumentative.¶

Commented [A19R18]: DEFENDANT RESPONSE: A critical purpose of individual voir dire in a high-profile case such as this is to ascertain what content the jurors have read and what they think they know about the case. The First Circuit’s well-reasoned opinion in Tsarmaev, currently pending before the U.S. Supreme Court explains why. It is insufficient simply to ask the jurors if they think they can be fair even after seeing media about the case. See, e.g., United States v. Tsarmaev, 968 F.3d 24, (1{sup}st Cir. 2020) (failure to ask each juror to identify what content they had already read about the case and to identify what they already thought they knew about the case grounds for reversal of death sentence), cert. granted, 141 S.Ct. 1683 (Mar. 22, 2021), oral argument scheduled (Oct. 13, 2021); Patriarca v. United States, 402 F.2d 314, 318 (1{sup}st Cir. 1968) (judge must elicit “the kind and degree” of each prospective juror’s exposure to the case or the parties’ if asked by counsel); [REDACTED] v. [REDACTED], 455 U.S. 209, 221-22 (1982) ([REDACTED] concurring) (prospective juror “may have an interest in concealing [their] own bias” or “may be unaware of it”).¶

Further, as in Tsarmaev decision, much of the information shared on the media about Ms. Maxwell and Mr. Epstein is either inaccurate or inadmissible, or pertains to persons and charges not before this jury. 968 F.3d at 58 (“while the media (social, cable, internet, etc.) gave largely factual accounts, some of the coverage included inaccurate or inadmissible information — like the details of his un-Miranda-ized hospital interview and the opinions of public officials that he should die”) (citation omitted). It also included a number of individuals’ personal opinions regarding Ms. Maxwell’s guilt.¶

Please identify by name (all that apply) Newspapers _____ Online News Sources _____ Magazines _____ Radio stations _____ Television/Cable stations _____ Streaming sources (Netflix, Peacock, Amazon, etc.) _____ Podcast providers _____ Internet Sites _____ Social media platform (Facebook, Instagram, Twitter, etc.) _____
Do you belong to any groups on social media (ex. Facebook or WhatsApp groups)? Yes   No   If Yes, please list the groups: _____
Have you ever posted messages, comments, or opinions on websites/social media, or blogged? Yes   No
If Yes, please describe the websites or social media platforms that you have used; the types of things you have posted or blogged; and how often you have done it: _____
Do you regularly watch any television shows, movies, dramas, documentaries, or docuseries (on any video platform) involving criminal investigations, crime solving, or criminal trials? Yes   No   If Yes, please identify the shows: _____
Please indicate your agreement or disagreement with the following: The media can be trusted to report both sides of controversial issues. Strongly agree   Agree   Disagree   Strongly disagree
Please identify by name any criminal cases have you followed in the media?

This case has been widely reported in the national and local media. There is nothing wrong with having heard something about this case. It is important to truthfully and fully answer all of the following questions.
Before coming here today have you read, seen, or heard anything about: Ghislaine Maxwell Yes No Jeffrey Epstein Yes No This Case Yes No
How closely have followed any reports about this case, Ghislaine Maxwell or Jeffrey Epstein? Very closely Somewhat closely Not closely Not at all
Please indicate the sources from which you have read, seen, heard, or received information about the case, Ghislaine Maxwell or Jeffrey Epstein? (check all that apply) Newspapers Books Magazines Television Radio Streaming Sites (Netflix, Peacock, Amazon, etc.) Podcasts Internet Social Media Chat Rooms Court Proceedings Talked with people Overheard people talking Other Sources (please list) _____
Please identify by name anything you read, viewed, or listened to regarding this case, Ms. Maxwell or Mr. Epstein: News articles _____ Books _____ Television Show _____ Documentaries _____ Docu-Series _____ Podcast _____

Summarize what you know or have heard about this case, Ghislaine Maxwell or Jeffrey Epstein:
	Please respond to the following based upon anything :
	Have you read, seen or heard anything you have read, seen, heard and discussed with family, friends, colleagues and co-workers, have you formed any impression or opinion about this case?
	Yes No If Yes, please state your impressions or opinions:
Have you personally formed an opinion about Ms. Maxwell’s guilt or innocence as a result of anything you have heard, read or seen? Yes No
If Yes, please state summarize your opinion:
Have you discussed this case with family, friends, colleagues, or co-workers
Yes No If Yes, summarized what was discussed:
Have you verbally stated or posted your opinion on social media about Ms. Maxwell or Mr. Epstein?
Yes No
If Yes, when and where did you state or post your opinion?
Before today, had you read, seen, or heard anything about criminal charges brought against Ms. Maxwell?
Yes No
If yes, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website):

10.	Aside from anything you may have read, seen, or heard about criminal charges brought against Ms. Maxwell, before today, had you read, seen, or heard anything about [REDACTED]
	Yes	No
	If yes, please state what you remember hearing, and how or from whom you may have heard about Ms. Maxwell (e.g., a friend, the newspaper, a website):
11.	Based on anything that you have read, seen, or heard about Ms. Maxwell, including anything about criminal charges against Ms. Maxwell, have you formed any opinions about Ms. Maxwell that might make it difficult for you to be a fair and impartial juror in this case?
	Yes	No
	Not applicable, I have not read/seen/heard about Ms. Maxwell
	If yes, please explain why it might be difficult for you to be a fair and impartial juror in this case:
12.	Before today, had you read, seen, or heard anything about Jeffrey Epstein?
	Yes	No
	If yes, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website):

	_____
13.	Based on anything that you have read, seen, or heard about Jeffrey Epstein, have you formed any opinions about Mr. Epstein that might make it difficult for you to be a fair and impartial juror in this case? Yes                      No Not applicable, I have not read/seen/heard about Mr. Epstein
	If yes, please explain why it might be difficult for you to be a fair and impartial juror in this case: _____ _____ _____ _____
14.	Based on anything you have read, seen, or heard about Ms. Maxwell, including anything about criminal charges brought against Ms. Maxwell, would you be able to follow the Court’s instruction to put that information out of your mind and decide this case based only on the evidence presented at trial? Yes                      No Not applicable, I have not read/seen/heard about Ms. Maxwell
	If no, please explain: _____ _____ _____ _____ _____
	When you first learned about this case, what were your reactions? _____
	Have your reactions changed since then? Yes                      No If Yes, please explain: _____
	Have you formed any opinion about:

Commented [A22]: GOVERNMENT OBJECTION: The Government objects to the next series of questions proposed by the defendant that are in [REDACTED] color font. The Government objects on the grounds that these questions would not provide a basis for a for-cause challenge and ask jurors to express opinions based on media coverage. If jurors have had reactions to media coverage, questions about their ability to be fair and impartial will address any questions about their ability to serve as jurors. The proposed questions inappropriately ask jurors to deliberate based on media reporting.¶

Commented [A23R22]: DEFENDANT RESPONSE: The defense incorporates by reference her response to the Government’s objection to her “media” related questions and the case law cited therein.¶

	This Case O Yes		❑ No
	Ghislaine Maxwell O Yes		O No
	Jeffrey Epstein O Yes		❑ No
O Yes	O No
❑	Definitely Guilty		❑ Probably Guilty O Probably Not Guilty
❑		Definitely Not Guilty	❑ Unsure/No Opinion ❑ Not enough information to
❑ Ycs	❑	No	If Yes. please explain:
❑ Ycs	❑	No	If Yes. please explain:
			I lave you discussed this case with anyone working for the media? O Yes ❑ No
❑ A lot		O A little	❑ None

	How accurate do you feel the reports about this case, in any medium, have been? Very accurate Somewhat accurate Not very accurate Not accurate Don’t know/No Opinion
	Do you think Ghislaine Maxwell’s association with Jeffrey Epstein will make it difficult for you fairly and impartially consider the evidence presented at trial and render a verdict based solely on the evidence? Yes No Unsure
	If Yes or Unsure, please explain: _____
	If you are selected as a juror in this case, would you be able to refrain from reading about, listening to, or watching any print, electronic media, or Internet coverage in this case? Yes No Unsure
	If Yes or Unsure, please explain: _____
15.	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
	If yes, please explain:
16.	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? Yes No
	If yes, what are your views or opinions, and would they affect your ability to serve as a fair and impartial juror?

	17. Do any of you have any opinion about the enforcement of the federal sex trafficking laws or the federal laws concerning sex crimes against minors that might prevent you from being fair and impartial in this case? Yes No
	If yes, please explain:
	18. Have you or a family member ever lobbied, petitioned, or worked in any other manner for or against any laws or regulations relating to sex trafficking or sex crimes against minors? Yes No
	If yes, please explain when and what you or your family member did:
	Whether reported or not, have you, any family member or anyone close to you, including a child/minor, ever been the victim of any form of sexual abuse? (This includes actual or attempted sexual assault or other unwanted sexual advance, including by a stranger, acquaintance, supervisor, teacher, or family member.) Yes No If yes, please explain:
	Whether reported or not, have you, or anyone close to you, including a child/minor, ever felt in danger of being sexually assaulted by another person, including a stranger, acquaintance, supervisor, teacher, or family member? Yes No If yes, please explain:
	Have you or anyone close to you ever participated in a class or discussion group, read books or articles listened to podcasts, or participated in blogs or chat rooms concerning sexual assault or sexual abuse? Yes No

Commented [A25]: GOVERNMENT OBJECTION: The Government objects to the next series of questions proposed by the defendant that are in [REDACTED] color font. The Government objects on the grounds that these questions are inappropriate, argumentative, confusing, and excessively detailed. The defendant’s proposed questions are not streamlined in accordance with the Court’s Order. The Government submits that its proposed questions ask the jurors what is necessary on the subject but is not as unduly burdensome as the defendant’s proposal.¶

Commented [A26R25]: DEFENDANT RESPONSE: Juror’s personal experiences (directly or indirectly through family members and close friends) with sexual misconduct has significant potential to bias their opinions towards Ms. Maxwell based on the allegations and evidence in this case. The privacy of a questionnaire affords an opportunity to share these biases confidentially and candidly and best allow the parties to identify who cannot be a fair juror in this case or allows the Court to decide whether individual questioning of that juror is appropriate, based on the sensitive nature of the content of the questions.¶

	If Yes, please explain: _____
	Have you ever made a claim of inappropriate sexual behavior of any kind (sexual harassment, sexual contact, sexual abuse, or sexual assault/rape)? Yes No
	If Yes, please explain: _____
	Have you ever been accused of any inappropriate sexual behavior of any kind (sexual harassment, sexual contact, sexual abuse, or sexual assault/rape)? Yes No
	If Yes, please explain: _____
	Has your spouse, significant other, any family member, friend, or co-worker ever made a claim of sexual harassment, sexual contact, sexual abuse, or sexual assault/rape? Yes No
	If Yes, please explain: _____
	Has your spouse, significant other, any family member, friend, or co-worker ever been accused of sexual harassment, sexual contact, sexual abuse, or sexual assault/rape? Yes No
	If Yes, please explain: _____
	Have you, any family members or close friends, ever suffered from post-traumatic stress disorder as a result of inappropriate sexual behavior? Yes No Unsure
	If Yes or Unsure, please explain the cause and, without using any names, identify who was involved: _____
	Do you belong to any organizations or groups that have as one of the primary purposes, advocating or promoting federal, state, or local legislation regarding sex abuse? Yes No
	If Yes, please identify the organization or group _____
	Are you active in the organization or group or its activities? Yes No
	If Yes, describe the extent of involvement and how often
	Have you, any family member or close friend, ever worked or volunteered at any sex abuse crisis center, sex abuse crisis hot line, sex abuse counseling center, or any related entity? Yes No
	If Yes, please identify: _____
	Are you familiar with political movements in response to sexual abuse, including but not

	limited to #MeToo, #TimesUp? Yes No If Yes, please explain: _____
	Have you, your spouse, significant other, any family, friend, co-worker been involved in or in any way supportive (financially, philosophically or politically) of organizations such as #MeToo, #TimesUp? Yes No If Yes, please explain: _____
	Have you ever attended a rally, fundraising event or other events concerning the treatment of women who have been sexually assaulted? Yes No If Yes, please explain: _____
	Have you ever contributed money or volunteered time to groups or organizations concerned with women’s issue, such as #MeToo, #TimesUp? Yes No If Yes, please explain: _____
	Have you or anyone you know had any contact with, worked for, volunteered with, used the services of, or contributed to any entity providing support to individuals claiming to have been sexually abused? Yes No If Yes, please explain: _____
	This case involves allegations of sexual assault and sex trafficking of minors. Would you feel uncomfortable if you are selected to sit on this case? Yes No If No, is there any experience that you or anyone close to you has had that may affect your ability to listen to the evidence and reach a fair verdict based only on the evidence or lack of evidence? Yes No If Yes, please explain: _____
	Is there any experience that you or anyone close to you has had that may affect how you might view a case such as this Yes No If Yes, please explain: _____

	Do you believe that anyone who discloses having been sexually abused must be telling the truth? Yes No Unsure If Yes or Unsure, please explain:
	Would you tend to believe the testimony of woman claiming sexual abuse more, less, or the same as any other witness? Believe more Believe less Believe the same Unsure
	Would you tend to believe the testimony of a defendant accused of sexual abuse more, less, or the same as any other witness? Believe more Believe less Believe the same Unsure
19. Have you ever been involved—as defendant, victim, or any other way—in a case involving sex trafficking or sex crimes against minors? Yes No
	If yes, without listing names, please explain the nature of the allegations, the approximate date(s), and the outcome, and indicate whether that would affect your ability to serve as a fair and impartial juror in this case: _____
	Yes No
20. Has a relative, close friend, or associate ever been involved—as defendant, victim, or any other way—in a case involving sex trafficking or sex crimes against minors? Yes No
	If yes, without listing names, please explain the nature of the allegations, the approximate date(s), and the outcome, and indicate whether that would affect your ability to serve as a fair and impartial juror in this case: _____
	Yes No
21. Have you ever been the victim of sexual abuse of any nature? Yes No
	If yes, please explain, and indicate whether that would affect your ability to serve as a fair and impartial juror in this case:

MENTAL HEALTH, LAW, LAW ENFORCEMENT
Have you, your spouse or significant other, family or close friends ever studied or received any mental health training? Yes No If Yes, please explain: _____
Have you ever had any employment or volunteer experience in any of the following areas? (Check each on that applies) Psychiatry Psychology Social Work Mental Health Therapy/Counseling Sex Abuse Counseling
Do you have any family or friends who are psychiatrists, psychologists, mental health therapists/counselors or sex abuse counselors? Yes No If Yes, do you often discuss their work with them? _____
Have you received any training in law, law enforcement or criminology? Yes No If Yes, please explain: _____
Have you ever had any employment or done any volunteer work in any of the following areas? (Check each one that applies to you) Law Enforcement Investigations Corrections/Jail/Prison Legal Profession Prosecution Criminal Defense Justice System/Courts Local/State/Federal Government
Do you have any family or friends who are in the legal or law enforcement profession? Yes No If Yes, do you often discuss their work with them? _____
Would you believe the testimony of a law enforcement officer simply because he/she is a law enforcement officer? Yes No If yes, please explain: _____
Would you favor the side that had law enforcement officers as witnesses? Yes No

Commented [A28]: GOVERNMENT OBJECTION: The defendant has proposed additional questions in this section in addition to the questions proposed below on consent. The additional questions proposed by the defendant are duplicative, unnecessarily burdensome, and overly detailed. In addition, questions about experience with mental health issues are not designed to screen for bias and are not appropriate for inclusion in a written questionnaire.¶

Commented [A29R28]: DEFENDANT RESPONSE: The defense-proposed questions are designed to identify individuals whose training, education and employment may cause the juror to follow their own independent knowledge and not follow the evidence actually presented at trial, or may reveal biases in favor of the Government.¶

If yes. please explain: __
22. Do you or any member of your family justice system, or the cowls?	or a close friend work in law, law enforcement, the
a Yes and impartial juror in this case:	o No
23. of New York?	Do you know or have any association—professional. business, or social, direct or indirect—
a Yes and impartial juror in this case•	o No
24.	Do you know or have any association—professional, business, or social, direct or indirect—
a Yes and impartial juror in this case:	o No
25.	Do you know or have any association—professional, business, or social, direct or indirect—
a Yes and impartial juror in this case:	o No

26. Have you. either through any experience you have had or anything you have seen or read.
a Yes	a No
27. Do you have any opinion of the U.S. Attorney’s Office for the Southern District of New
York or the U.S. Attorney Damian	that might make it difficult for you to be a fair
28. Do you have any opinions about prosecutors or criminal defense attorneys generally that

29.	Do you have any opinion about the criminal justice system generally or the federal criminal justice system in particular that might make it difficult for you to be a fair and impartial juror in this case? Yes No
	If yes, please explain:
CLOSING QUESTIONS
	Do you think Ghislaine Maxwell’s association with Jeffrey Epstein will make it difficult for you fairly and impartially consider the evidence presented at trial and render a verdict based solely on the evidence? Yes No Unsure If Yes or Unsure, please explain: _____
	Do you think what you have heard, seen, and read about Ghislaine Maxwell make it difficult for you fairly and impartially consider the evidence presented at trial and render a verdict based solely on the evidence? Yes No Unsure If Yes or Unsure, please explain: _____
	If you were a party to this case - either the prosecution or Ms. Maxwell - is there any reason you would not want yourself to be a juror? Yes No Unsure If Yes or Unsure, please explain: _____
	Some people who are called for possible jury service want to be chosen while others do not. How do you personally feel? (Please check one.) Very strongly want to serve Somewhat want to serve Indifferent Opposed to serving Strongly opposed to serving Would be difficult to serve Please explain your feelings: _____
	If you were convinced, at the conclusion of the trial, that Ms. Maxwell is either guilty or not guilty of the crimes charged, and a majority of the jurors disagreed with you, would you change your verdict simply because you were in the minority? Yes No Unsure If Yes or Unsure, please explain: _____ Is there anything that has come up in this questionnaire that creates doubt in your mind about whether you could be a fair, objective, and impartial juror in this particular case? Yes No

Commented [A30]: GOVERNMENT OBJECTION: The Government objects to the questions proposed by the defendant in the “Closing Questions” section. The Government does not believe these questions should be included in the written questionnaire because these questions will not provide a basis for a for-cause challenge. Some of the questions proposed by the defendant are duplicative of prior questions. Many of the questions are inappropriate, argumentative, confusing, and excessively detailed.¶

Commented [A31R30]: DEFENDANT RESPONSE: The questions are designed to identify persons for whom a for-cause challenge may be sustained by this Court. The Government has not identified any particular question that is “inappropriate, argumentative, confusing, and excessively detailed,” nor have they proposed limiting language that would cure any such problem.¶

If yes, please explain: in this case? case:
o Yes a No Iiyes. please explain:
Do you believe you should not serve as a juror in this case? o Yes If Yes or Unsure, please explain:	a No a Unsure
Do you believe you should serve as a juror in this cast? o Ycs If Yes or Unsure, please explain:	❑ No o Unsure
instructed by the Court? o Yes If Yes or Unsure, please explain:	o No o Unsure
allegation of sexual assault and sex trafficking of minors? o Yes	❑ No a Unsure
to be a juror in this case? o Yes If Yes or Unsure, please explain:	a No a Unsure
a juror in this case? o Ycs If Yes or Unsure, please explain:	❑ No a Unsure
Yes ❑ No o Unsure II Yes or Unsure, please explain:

objective, and impartial juror in this particular case? o Ycs If Yes. please explain:	o No
(II Yes o No If Yes, please list which question number(s):
Is there any matter you wish to discuss privately with the Judge? If Yes, please explain:	❑ Yes n No
considering you as a juror in this case? o Ycs If Yes, please explain:	❑ No
be tempted to disregard this instruction? o Yes If Yes, please explain:	❑ No
in the jury room, would you have ditliculty in following that instruction? a Ycs If Yes. please explain:	❑ No

DECLARATION¶

(juror number) declare under penalty of perjury that the foregoing answers set forth in this Jury Questionnaire are true and correct to the best of my knowledge and belief. I have not discussed my answers with others, or received assistance in completing the questionnaire.¶

Signed this day of November, 2021¶

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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