DATE: 3/8/22 TIME: CASE: 200330, US v. Maxwell Juror ID: 50 | USDC SDNY | | --------------------------- | | DOCUMENT | | ELECTRONICALLY FILED | | DOC #: | | DATE FILED: 3/9/22 | Post-verdict having 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 rift CASE The Court is selecting a jury for atrial 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 acriminal 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 aminor. 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 acriminal 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 acriminal 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 acriminal offense. Count Four charges the Defendant with transporting aminor to engage in sexual activity for which a person can be charged with acriminal offense, and aiding and abetting the same. Count Five charges the Defendant with participating in asex 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: 5o ## 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}`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 {sup}`a`jury to be one of the highest duties acitizen owes to the United States. Mere inconvenience or the usual financial hardship of jury service will not be sufficient to excuse {sup}`a`prospective juror. You must show extraordinary personal or financial hardship to be excused from service. **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):
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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):
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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:
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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.:
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.
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:
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:
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: |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: |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: |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, | p | laintiff, | or | | defendant? | | | | | | ❑ Yes | | (self) | | ❑ | Yes | (friend | or | family | | member) | | | X | No | | | 20a | If | yes, is | there | | any thing | about | | that | experience | that | would | | preven | t you | from | | acting as | | | a fair | and | | impartial | juror | in | this | case? | | | | | | | | | | | | | | | | ❑ | Yes | | | | | ❑ No | | | | | | | | 20b | If | yes to | 20a, | p | lease | exp lain: | | | | | | | | | | | | | 21 | | Have | you | or any | | relative | or | close | friend | ever been | | involved | or | | appeare | d as | a witness | | | in | any | | investigation | | by a | federal | or | state | gran d | jury or | by a | | congress | ional | or | state | | | | legislative | | | committee, | | licensing | | authority, | or | governmen | tal | | agency, | or | been | | | | ques | | tioned | in | any | matter | by any | federal, | | state, | or local | law | | enforcement | | | agency ? | | | | ❑ | Yes | (self) | | | ❑ | Yes | (friend or | family | | member) | | | | X | No | | 21a | If | yes, | is | there | any | thing | about | that | experience | that | would | preven | t | you | from | acting | as | | ----- | ---- | ------ | ------ | ---------------- | ----------- | ---------------- | ----------- | --------- | ------------ | ------------ | ----------- | --------- | ----------- | ----- | ---------- | --------- | ----------- | | | a | fair | and | | impartial | juror | in this | case? | | | | | | | | | | | | | | | | | o Yes | | | | | o No | | | | | | | | 21b | If | yes | to | 21a, | p | lease explain: | | | | | | | | | | | | | 22 | | Have | you, | or | has | any | relative | or | close | friend, | ever been | | subpoenae | d | for | any | inquiry | | | or | | | investigation? | | | | | | | | | | | | | | | | | o | Yes | | (self) | | o | Yes | (friend | or family | | member) | | | ‘11 | , No | | | 22a | If | yes, | is | there | any | thing | about | that | | experience | that | would | preven | t | you from | acting | as | | | a | fair | and | | impartial | | juror in | this | case? | | | | | | | | | | | | | | | | o | Yes | | | | a | No | | | | | | | 22b | If | yes | to | 22a, | p | lease | exp lain: | | | | | | | | | | | | 23 | | Have | | you, | or has | any | relative | or | close | fr iend, | ever | been | arrested | or | | charged | with a | | | | | o | Yes | (self) | | | o Yes | (friend | or | family | member) | | | | KNo | | | 23a | | If | yes, | is | there | any | thing | about | that | experience | that | would | preven | t | you | from | acting as | | | | a | fair | and | impartial | | juror | in this | case? | | | | | | | | | | | | | | | | o | Yes | | | | o | No | | | | | | | 23b | | If | yes | to | 23a, p | lease | exp | lain: | | | | | | | | | | Juror ID: so | 24 | Have | you, | | or | has | any | relative | or close | friend, | ever | been | the | subject | | of any | | | | ----- | ------ | --------------- | ------------- | ----------- | ----------- | ------------ | ----------- | ------------ | ------------ | ------------- | ----------- | ----------- | --------- | ----------- | ----------- | -------------- | ------------ | | | | investigation | | or | | accusation | by | any | gran d | jury, state | or | federal, | or | any | other | | | | | | o | Yes | (self) | | | o | Yes | (friend | or family | | member) | | | | XNo | | | 24a | If | yes, | is | there | any | thing | about | that | experience | that | would | | preven | t you | from | acting | as | | | a | fair | and | impartial | | juror | in | this case? | | | | | | | | | | | | | | | | | o | Yes | | | | o No | | | | | | | | 24b | If | yes | to 24a, | p | lease | exp | lain: | | | | | | | | | | | | 25 | | Have | you, | or | any | of | your | relatives | or close | friends, | | ever been | a | | victim of | a | crime? | | | | o | Yes | | (self) | | o | Yes | (friend | or family | | member) | | | | XN° | | | 25a | If | yes, | is | there | any | thing | about | that | experience | | that | would | preven | t | you | from | acting as | | | a | fair | and | | impartial | | juror in | this | case? | | | | | | | | | | | | | | | | o | Yes | | | | o | No | | | | | | | 25b | If | yes | to | 25a, | p | lease | exp lain: | | | | | | | | | | | | 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, | | | | | agenc | ies, | or | emp | loyees | of | the | United | States, | including | the | | United | States | | Attorney's | | | | Office, | | the | FBI, | or | the NYPD? | | | | | | | | | | | | | | | o | Yes | (self) | | | a Yes | (friend | or | family | member) | | | | X No | | | 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: |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
| | 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:
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| | 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:
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| | 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
| Juror ID: 5O | 44a. |If yes, please explain:
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:
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:
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:
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):
& 00000< & 00000> & 00000<< & 00000>
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