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Court filing · Nov. 2021

Preliminary instructions for the Ghislaine Maxwell jury questionnaire, November 2021

Court-issued preliminary instructions for prospective jurors in Ghislaine Maxwell's November 2021 trial, summarizing her six counts and swearing jurors to truthful answers.Machine-written summary

EXHIBIT 1

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.

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 areasonable 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 aminor to travel to engage in sexual activity for which {sup}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 aminor 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 areasonable doubt.

Juror ID: 5 - 0

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, {sup}2021 (Christmas Eve Day) and Friday, December 31, 2021 (New Year’s Eve).

If you are selected as {sup}ajuror, 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 {sup}ajury 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 {sup}aprospective juror. You must show extraordinary personal or financial hardship to be excused from service.

Juror ID: 5 111)

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:

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.:






No
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.






No
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:






No
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:







BASICLEGALPRINCIPLESANDMEDIARESTRICTIONS
10 Underthelaw,thefactsarefor thejuryto determineandthelaw isforthe Judgeto
determineYouarerequiredto acceptthelawas theJudgeexplainsit toyoueven if
youdo notlikethelawordisagreewithit, andyoumustdeterminethefacts
accordingtothoseinstructionsDoyouacceptthisprinciple,andwill youbeable to
followtheJudge’sinstructionsifselectedtoserve onthisjury?
YesoNo
10a If no,pleaseexplain:
II Thelawprovidesthatadefendantinacriminalcaseispresumedinnocentatall
stagesofthetrialandisnotrequiredtoput onanydefenseatallThe Government
is requiredto provethedefendantguiltybeyondareasonabledoubtoneachcharge
Doyouaccepttheseprinciples,andwillyoube abletoapplythemif selectedto
serveonthisjury?
XYesoNo
1 I a Ifno, pleaseexplain:

Juror ID: go

12 Thelaw providesthatadefendantina criminalcasehasan absoluterightnotto
testify,andthata jurorcannotholditagainstthe defendantifshechoosesnotto
testifyDoyouacceptthisprinciple,andwillyoube abletoapplyit ifselectedto
serveon thisjury?
Ys,Yes❑No
12a If no,pleaseexplain:
13 A jurorisrequiredby lawtomakehisorherdecisionbasedsolelyonthe evidence
or lackofevidencepresentedinCourt,andnotonthebasisof conjecture,suspicion,
bias,sympathy,orprejudiceDoyouacceptthisprinciple,andwill yoube ableto
applyitif selectedto serveon thisjury?
Y \Yes❑ No
13a If no,pleaseexplain:
14 Underthelaw,thequestionofpunishmentisfortheCourtaloneto decide,and thus
theissueofpun ishmentmustnotenterintoyourdeliberationsas to whetherthe
defendantisgu iltyornot guiltyaschargedDoyouacceptthisprinciple,andwill
youbeableto applyit if selectedtoserveonthisjury?
`54Yeso No
14a Ifno, pleaseexplain:
15 Youmayheartestimonyin thiscase thatlawenforcementofficersrecoveredcertain
evidencefromsearchesThe Courtwillinstructyou thatthosesearcheswere legal
andthattheevidenceobtainedfrom thosesearchesisadmissibleinthis caseDo
youhaveanyfeelingsorop inionsaboutsearchesconductedbylawenforcement
officers,or theuseofevidenceobtainedfromsearches,thatwouldaffectyour
abilitytobefair andimpartial inthiscase?
❑ YesX No
15a Ifyes, pleaseexplain:
16 YoualsomayheartestimonyinthiscasefromexpertwitnessesHave youhad any
experienceswithexperts,or doyouhave anygenera lfeelingsabouttheuse of
experts,thatwouldaffectyourabilityto befairandimpartialin thiscase?
❑ Yesx No
16a Ifyes,p leaseexplain:
17 Asinstructedabove,from nowanduntilyourjuryserviceis complete,you are
instructedtoavoidallmediacoverageandnotto goon theInternetwithregar d to
this caseforanypurposeThatis, youareforbiddenfromconsuminganynews
mediaorsocialmedia,or anydiscussionofthiscase(or ofanyoneparticipating in
the case)outsideof thecourtroomwhatsoeverYoualso mustnotdiscussthis case
withanyoneThisincludesyourfamily,friends,spouse,domesticpartner,
colleagues,and co-workersTheseinstructionsapp lyfromnow anduntilyou are
eitherdismissedfromjuryselectionorchosenas ajuror andthetrial iscomp lete
Whenwereturnfor thenextstep injuryselection,theJudgewillask youif you
havefollowedthisinstruction
Do youhaveanyreservationsorconcernsaboutyourabilityorwillingnessto
followthisinstruction?
❑Yes)(No
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

EXPERIENCEASAWITNESS,DEFENDANT,ORCRIMEVICTIM
20Haveyou, orhasanyrelativeorclosefriend, everparticipatedinastateorfederal
courtcase,whethercriminalorcivil ,as awitness,plaintiff,ordefendant?
o Yes(self)oYes(friendorfamilymember)XNo
20aIfyes, isthereanythingaboutthat experiencethatwouldprevent youfromacting as
afair andimpartialjuror inthiscase?
oYesa No
20bIfyes to20a,pleaseexplain:
21Have youor anyrelative orclosefriendever beeninvolvedorappearedasa witness
inanyinvestigationby afederalorstategran djury orby acongressionalorstate
legislativecommittee,licensingauthority,orgovernmentalagency,orbeen
questionedinanymatter byanyfederal,state,or locallawenforcementagency ?
aYes(sell)a Yes(friend orfamilymember)XNo
21aIfyes,isthereanythingaboutthatexperiencethatwouldpreventyoufromactingas
afairandimpartialjuror inthiscase?
o Yeso No
21bIfyesto21a,pleaseexplain:
22Haveyou,or hasany relativeorclosefriend,ever beensubpoenaedforanyinquiry
orinvestigation?
oYes(self)o Yes(friendorfamilymember)NA,No
22aIf yes,isthereanythingaboutthatexperiencethatwouldpreventyoufromacting as
afairandimpartialjuror inthiscase?
o YesoNo
22bIf yesto22a,pleaseexplain:
23Haveyou ,or hasanyrelativeor closefriend,everbeenarrestedorchargedwith a
oYes(self)oYes(friendorfamilymember)%No
23aIfyes,isthereanythingaboutthatexperiencethatwouldpreventyoufromacting as
a fairandimpartialjurorin thiscase?
o YesoNo
23bIfyesto23a, pleaseexplain:
24 Haveyou,or hasanyrelativeorclosefriend,everbeenthesubjectof any
investigationoraccusationbyany grand jury,state orfederal,or anyother
oYes(self)❑ Yes(friendorfamilymember))(No
24a If yes,isthereany thingaboutthat experiencethatwouldpreventyou from acting as
a fairandimpartialjurorin thiscase?
❑YesoNo
24b If yesto24a, pleaseexplain:
25 Haveyou,orany ofyourrelativesorclosefriends,everbeenavictim of a crime?
❑ Yes(self)❑Yes(friendorfamilymember)X N°
25a If yes,isthereanythingaboutthatexperiencethatwouldpreventyou from acting as
a fairandimpartialjurorin thiscase?
❑Yes❑No
25b Ifyes to25a,p leaseexplain:
26 Haveyou,orhas anymemberofyourfamilyor anyofyourclosefriends either as
individualsorin thecourseoftheirbusinessaffairs—everbeen aparty to a legal
actionordisputewiththeUnitedStates,or withanyoftheofficers,departments,
agencies,oremployeesof theUnitedStates,includingtheUnitedStates Attorney’s
Office,the FBI,ortheNYPD?
❑Yes(self)oYes(friendorfamilymember)X No

Juror ID: 6 -0

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:




Juror ID: 6 0

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:





_____
Yes No
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 Yes
29a.If yes, please explain:





_____
Yes No
29b.If yes to 29, would this affect your ability to serve as a fair and impartial juror in this case?

Yes
No Yes
29c.If yes to 29b, please explain:





_____
Yes No
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 Yes
30a.If yes, please explain:





_____
Yes No

Juror ID: 6 0

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?
31a.If yes, please explain: Yes No
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 [REDACTED], 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?
32. Yes No

Juror ID: go

32a.If yes, please explain:
PERSONALRELATIONSHIPWITHCASEPARTICIPANTS
33Thenextsubsetofquestionsaskswhetheryouoranymemberofyourfamilyor a
closefriendpersonallyknowsor haspas torpresentdealingswithindividuals
involvedin thiscaseTo”personally know”meansto havesomedirectorpersona l
knowledgeorconnectionto thefollowingindividualsIfyou haveonlyheardthe
namesthroughmediaorsocialmedia,forexample,that isnotpersona lknowledge
33aDoyouordoesanymemberofyourfamilyoraclosefriendpersonallyknowor
havepas torpresent dealingswiththeDefendantinthiscase,GhislaineMaxwell, or
herfamilymembers?
o YesXNo
33bDoyouordoesanymemberofyourfamilyoraclosefriendpersonallyknowor
havepas torpresentdealingswithJeffreyEpstein?
o YesXNo
33cDoyouordoes anymemberof yourfamilyora closefriend pernallvknow or
havepast orpresent1’the U.SAttorneyfortheSouthernDistrictof
NewYork,Damian,theformerActingU.SAttorneyfor theSouthern
DistrictofNewYork,AudreyStrauss,oranyoneelse whoworksfororused to
workfortheU .SAttorney’sOfficefortheSouthernDistrict ofNewYork?
oYesXNo
33dDoyouordoesanymemberofyourfamilyoraclosefriendpersonallyknow or
havepast orpresentdealingswithanyof theAssistantUnitedStatesAttorneyswho
areprosecutingthis case:
MaureneComeyo YesXNo
AlisonMoeo YesXNo
LaraPomerantzo YesXNo
AndrewRohrbacho Yes)(No

Juror ID: 6-0

33eDoyouordoesanymemberofyourfamily oraclosefriendpersonallyknowor
havepastorpresentdealingswithany ofthedefenseattorneys orlawfirmswho are
representingtheDefendant:
ChristianEverdellof&GresselLLP❑ Yes)<No
JeffreyPagliucaofHaddon,—and,P .Ca YesNo
LauraMenningerofHaddon,IIIIIIand, P .C❑Yes)(No
BobbiSternheimofLawOfficesofBobbiCStemheim❑ YesX No
33fDoyouor doesanymemberofyourfamilyora closefriendpersonallyknow or
havepastorpresentdealingswiththeUnitedStatesDistrictCourtJudgewho is
presidingoverthiscase,AlisonJNathan, oranyonewhoworkson herstaff?
o YesyNo
33gIfyouanswered”yes” toanyofthe abovesub-questions(33a,33b, 33c,33d, 33;
or 33f),pleaseexplainwhomyouknow,howyouknowtheindividual(s),and
whetheryourrelationshipwiththatpersonmightmake itdifficultforyouto be a
fairandimpartialjurorin thiscase:
KNOWLEDGEOFCASEANDPEOPLE
Thiscasehasbeenwidelyrepor tedinthenationalandlocal mediaThereis
nothingwrongwithhavingheardsomethingaboutthiscase Itisimportant to
answerall ofthefollowingquestionstruthfullyandfully
34Beforetoday,hadyou read,seen,orheardanything aboutMsMaxwell?
)itYesaNoo Unsure
34a Ifyes orunsure,pleasestatewhatyourememberhearing,andhowor fromwhom
youmayhaveheard(e .g, afriend,thenewspaper,awebsite,socialmedia)If you
heardabout MsMaxwellfromamediasource,p leaseidentifythemediasource by
S`0Cla1Y\C),websiteAtrukS‘A.st.Was
3 c4N-te ut9 5ktli -%C3i c‘ci ‘l -telt\—sourceLi0,3
CNNcoWN
35Haveyoupersonallyformedan opinionaboutMsMaxwell’sguilt orinnocence of
thecrimeschargedas aresultofanythingyouhaveheard,read orseen?
oYes)(NoaUnsure
oNotapplicable,Ihavenotread/seen/heardabout MsMaxwell
35aIf yesor unsure,pleasesummarizeyourop inion:
36Basedonany thingthatyouhaveread,seen,orheardaboutMsMaxwell,including
anythingaboutcriminalchargesagainstMsMaxwell,haveyouformedany
opinionsabout MsMaxwellthatmightmake itdifficultforyou tobea fairand
impartialjuror inthiscase?
o Yes%NoaUnsure
a Notapplicable,Ihavenotread/seen/heardabout MsMaxwell
36aIf yesorunsure,p leaseexplainwhyitmight bedifficultforyouto beafair and
impartialjuror inthiscase:
37Beforetoday,had youread,seen,orheardanythingaboutJeffreyEpstein?
XYesoNoaUnsure
37aIf yesorunsure,p leasestatewhatyourememberhearing,and howorfromwhom
youmayhaveheard (e.g ,afriend,thenewspaper,awebsite,socialmedia)If you
heardaboutMrEpsteinfroma mediasource,p leaseidentifythemediasource by
C.0 1 \11 .35Ocl(C C\ecka\abCAAtSirc,k 3afoTh
OMkArvPACV.A.Lim1(‘)0AChk).1O, \ 1WY3t(%Ca ,
38Haveyouverballystatedorpostedyouropinion onsocialmediaoronlineabout
MsMaxwellor MrEpstein?
OYes’No
ONot applicable,Ihave notread/seen/heardabout MrEpstein/MsMaxwell
38aIfyes,whenand wheredidyoustateor pos tyour opinion?
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

Juror ID: 5 - 0

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

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:






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:






Juror ID: 6°

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:

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):




DECLARATION

I, Juror Number declare under penalty of perjury that the foregoing answers set forth in this Jury Questionnaire arc 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 {sup}14141 day of November, {sup}2021

DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER.

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.

| ---------------------------------------- |

| ---------------------------------------- |

Preliminary instructions for the Ghislaine Maxwell jury questionnaire, November 2021

Court filings

Court-issued preliminary instructions for prospective jurors in Ghislaine Maxwell's November 2021 trial, summarizing her six counts and swearing jurors to truthful answers.

Court Records: United States v. Maxwell (S.D.N.Y. 1:20-cr-00330) · Nov. 2021

EXHIBIT 1 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…