Jury questionnaire preliminary instructions in United States v. Maxwell, juror 50

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}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 acitizen 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.¶

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.:
6.	Do you have any difficulty reading, speaking, or understanding English? Yes No
7.	Do you have any medical, physical, or mental condition or illness that makes you unable to serve on a jury, including difficulty hearing, seeing, reading, or concentrating? Yes No
7a.	If yes, please briefly describe the condition or illness. If you believe you could serve as a juror if such condition were accommodated in some way, please state the accommodation.
8.	Are you taking any medication which would prevent you from giving full attention to all the evidence at this trial? Yes No
8a.	If yes, please explain:

Juror ID: 5-CI¶

9.	Do you have any religious, philosophical, or other beliefs that would make you unable to render a verdict in a criminal case? Yes No
9a.	If yes, please explain:

			BASIC		LEGAL		PRINCIPLES		AND		MEDIA		RESTRICTIONS
10	Under	the	law,	the	facts	are for	the	jury	to	determine	and	the law	is for	the	Judge to
	determine		You	are	requ	ired to	accep	t	the law	as	the Judge	exp lains	it	to you	even if
you	do	not	like	the	law	or	disagree	with	it, and	you	must	determine	the	facts
	according		to	those		instructions	Do	you	accep	t this	principle,	and	will	you	be able to
	follow	the		Judge’s		instructions	if	selected	to	serve	on this	jury?
					1k	Yes				o	No
10a If	no,	p	lease	exp	lain:
II	The	law	prov	ides	that	a	defendant	in a	criminal		case is	presume d		innocent	at all
	stages	of	the	trial	and	is not	requ ired	to	pu t	on any	defense	at all	The		Government
	is requ		ired to	prove	the		defendant gu		ilty	beyond	a	reasonable	doubt	on	each charge
	Do	you	accep	t	these	principles,	and	will	you	be	able to	app ly them	if	selected	to
	serve	on	this	jury?
						)(Yes					o No
I la	If no,	p	lease	exp	lain:

Juror ID: g °¶

12.	The law provides that a defendant in a criminal case has an absolute right not to testify, and that a juror cannot hold it against the defendant if she chooses not to testify. Do you accept this principle, and will you be able to apply it if selected to serve on this jury?	Yes	No
12a.	If no, please explain:
13.	A juror is required by law to make his or her decision based solely on the evidence or lack of evidence presented in Court, and not on the basis of conjecture, suspicion, bias, sympathy, or prejudice. Do you accept this principle, and will you be able to apply it if selected to serve on this jury?	Yes	No
13a.	If no, please explain:
14.	Under the law, the question of punishment is for the Court alone to decide, and thus the issue of punishment must not enter into your deliberations as to whether the defendant is guilty or not guilty as charged. Do you accept this principle, and will you be able to apply it if selected to serve on this jury?	Yes	No
14a.	If no, please explain:

15 You	may	hear		testimony	in this	case that	law		enforcement	officers		recovered	certain
	evidence	from	searches		The Court	will	instruct		you that	those	searches		were legal
and	that	the	evidence		obtained	from those		searches	is	admissible	in	this case	Do
you	have	any	feelings	or	op inions	about		searches	conducted	by	law	enforcement
	officers,	or the	use	of	evidence	obtained	from		searches,	that	would	affect	your
ability	to	be	fair and		impartial in	this	case?
				❑ Yes					X No
15a If	yes, p	lease	exp	lain:
16 You	also	may	hear	testimony	in	this	case	from	expert	witnesses		Have you	had any
	experiences		with	experts,	or do	you	have any		genera l	feelings	about	the	use of
	experts,	that	would	affect	your	ability	to be	fair	and	impartial	in this	case?
				❑ Yes					?” ` No
16a If	yes, p	lease	exp	lain:
17 As		instructed	above,		from now	and	until	your	jury	service	is comp	lete,	you are
	instructed	to	avoid	all	media	coverage	and	not	to go	on the	Internet	with	regar d to
	this	case for	any	purpose	That	is, you	are	forbidden		from	consuming	any	news
	media	or	social	media,	or any	discussion	of	this	case	(or of	anyone	part	icipating in
	the	case)	outside	of the	courtroom		whatsoever		You	also must	not	discuss	this case
	with	anyone	This	includes	your	family,		friends,	spouse,		domestic	partner,
	colleagues,		and co	-workers		These	instructions		app ly	from	now	and until	you are
	either	dismissed		from	jury	selection	or	chosen	as a	juror and	the	trial is	comp lete
	When	we	return	for the	next	step in	jury	selection,	the	Judge	will	ask you	if you
	have	followed		this	instruction
	Do you	have	any		reservations	or	concerns	about	your	ability	or	willingness	to
	follow	this		instruction?
				❑	Yes					No

17a.	If yes, please explain:

PRIOR JURY SERVICE
18.	Have you ever served as a juror in a trial in any court? Yes No
19.	Have you ever at any time served as a member of a grand jury, whether in federal, state, county, or city court? Yes No

			EXPERIENCE		AS	A	WITNESS,			DEFENDANT,		OR	CRIME			VICTIM
20	Have	you,	or	has	any	relative	or	close	friend,	ever		participated	in	a	state	or	federal
	court	case,		whether		criminal	or	civil, as	a	witness,	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:
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°¶

28b.	If yes to 28, would this affect your ability to serve as a fair and impartial juror in this case?	Yes	No
28c.	If yes to 28b, please explain:
29.	Do you know or have any association—professional, business, or social, direct or indirect—with any member of the staff of the United States Attorney’s Office for the Southern District of New York?	Yes	No
29a.	If yes, please explain:
29b.	If yes to 29, would this affect your ability to serve as a fair and impartial juror in this case?	Yes	No
29c.	If yes to 29b, please explain:	_____
30.	Do you know or have any association—professional, business, or social, direct or indirect—with the Federal Bureau of Investigation, commonly known as the FBI?	Yes	No
30a.	If yes, please explain:	_____

30b.	If yes to 30, would this affect your ability to serve as a fair and impartial juror in this case?	Yes	No
30c.	If yes to 30b, please explain:		31. Do you know or have any association—professional, business, or social, direct or indirect—with the New York City Police Department, commonly known as the NYPD? Yes No
31a.	If yes, please explain:		31b. If yes to 31, would this affect your ability to serve as a fair and impartial juror in this case? Yes No
31c.	If yes to 31b, please explain:		32. Do you have any opinion of the U.S. Attorney’s Office for the Southern District of New York, the U.S. Attorney Damian [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? Yes No

Juror ID: 6-0¶

| 32a. | If yes, please explain:¶

---

---

---

_____ |¶

------	-------------------------------------------------------------

					PERSONAL			RELATIONSHIP		WITH			CASE	PARTICIPANTS
33	The	next		subset	of	ques	tions asks		whether	you	or	any	member	of	your family	or a
	close		friend		personally		knows or	has	pas t	or	presen	t	dealings	with	individuals
		involved	in	this	case	To	”personally		know”		means	to	have	some	direct or	personal
		knowledge		or		connection	to the		following		individuals		If	you have	only heard	the
		names		through	media	or	social	media,	for	examp		le,	that is	not personal		knowledge
33a	Do	you	or	does	any	member	of	your	family	or	a	close	friend	personally	know	or
	have		pas t	or	presen	t dealings		with	the	Defendant		in	this	case, Ghislaine		Maxwell, or
	her		family		members?
						o Yes						)e(	No
33b	Do	you	or	does	any	member	of	your	family		or a	close	friend	personally	know	or
		have	pas t	or	presen	t	dealings	with	Jeffrey		Epstein?
						a Yes						)4(	No
33c		Do	you	or	does	any	member	of	your	family	or	a	close	friend	personally	know or
		have	pas	t or	presen	t dealin	s	with	the U	.S		Attorney	for	the Southern	District	of
		New	York,		Damian			the	former		Acting	U	.S	Attorney	for the	Southern
		District		of	New	York,	Audrey		Strauss,	or	anyone		else who	works	for or	used to
		work	for	the	U .S	Attorney	’s	Office	for	the		Southern		District of	New York?
						o	Yes					)1(	No
33d		Do	you	or	does	any	member	of	your	family	or	a	close	friend	personally	know or
		have	pas	t or	presen	t	dealings	with	any	of the		Assistant		United	States	Attorneys who
		are	prosecu		ting	this case:
					Maurene	Convey			a Yes				)(No
				Alison		Moe			o Yes			X	No
				Lara		Pomerantz			a	Yes		X	No
					Andrew	Rohrbach			a	Yes			)(No

Juror ID: 5 °¶

33e	Do	you	or	does	any	member	of	your	family	or	a	close	friend	persona	lly	know	or
		have	pas t	or	presen	t dealings		with	any of	the		defense	attorneys	or	law	firms	who are
		represen		ting the		Defendant:
				Christian		Everdell	of		8c	Gresser		LLP			❑ Yes	g	No
				Jeffrey		Pagliuca	of	Haddon,			and	Milli		P .C	❑ Yes	bi	.( No
				Laura		Menninger	of	Haddon,			and	el	,	P .C	o	Yes	)(No
				Bobbi		Sternheim	of Law		Offices	of	Bobbi	C	Sternheim		❑	Yes	)4No
33f.		Do	you	or does	any		member of	your		family	or a	close	friend	persona	lly	know	or
		have	pas t	or	presen	t	dealings	with	the	United		States	District	Court	Judge		who is
		pres	iding	over	this	case,	Alison	J	Nathan,	or		anyone	who	works	on her	staff?
						❑ Yes						YNo
33g	If	you		answered		”yes”	to any	of	the above		sub	-ques	tions	(33a,	33b, 33c,	33d,	33e,
		or	330, p	lease	exp	lain	whom	you	know,	how		you	know the		individual(s),		and
		whether		your		relationship	with	that		person	might		make it	difficult	for	you	to be a
		fair	and	impartial		juror	in this	case:

					KNOWLEDGE			OF	CASE	AND	PEOPLE
This	case	has	been	widely		reporte	d in		the national		and	local media		There is
	nothing	wrong	with	having		heard		something		about	this	case It	is	important to
	answer	all of	the	following		ques	tions		truthfully	and	fully
34	Before	today,	had you	read,		seen, or		heard	any	thing about	Ms		Maxwell?
			Y ,	Yes		o	No			o Unsure
34a If	yes or	unsure,	p	lease	state	what	you		remember	hearing,	and	how	or from	whom
you	may	have	heard	(e .g .,	a	friend,	the		newspaper,	a	website,	social	media)	If you
	heard	about Ms		Maxwell	from	a	media		source,	p lease	identify	the	media	source by
S	q	kuji	V \	0,	we)	.06‘te			lintk		5\fk.t.	Was
	”SPRC	re L.\	V	9 s -ks	?os		()I c	‘k	(c,tetl	—		3ourc e	eiet3
	CNN	, Cr	VV\
35	Have	you	persona	lly	formed	an op		inion	about	Ms	Maxwell’s	gu	ilt or	innocence of
	the	crimes	charged	as a	result	of	any	thing	you	have	heard,	read or	seen?
		o	Yes		)(No			o	Unsure
		o	Not	app	licable,	I	have	not		read/seen/heard		about Ms	Maxwell
35a	If yes	or	unsure, p	lease		summarize		your	op inion:

Juror ID: 5-(:)¶

36	Based	on any	thing	that	you	have		read,	seen,	or	heard	about Ms		Maxwell,		including
	any	thing	about	criminal		charges		against	Ms		Maxwell,	have	you	formed	any
	op inions		about Ms		Maxwell		that	might		make it	difficult	for	you to	be	a fair	and
	impartial		juror in	this	case?
			o Yes		”K No			o	Unsure
			o Not	app	licable,		I	have	not		read/seen/heard	about	Ms		Maxwell
36a	If yes	or	unsure,	p lease	exp	lain		why	it	might be	difficult	for	you to	be	a fair	and
	impartial		juror in	this	case:
37	Before		today,	had you	read,		seen,	or	heard	any	thing	about	Jeffrey		Epstein?
			X	Yes		o	No			o	Unsure
37a	If	yes or	unsure,	p lease		state		what	you	remember		hearing,	and how	or	from	whom
	you	may	have	heard (e	.g .,	a		friend,	the	newspaper,	a	website,		social	media)	If you
	heard	about	Mr	Epstein		from		a media		source,	p lease	identify	the		media	source by
	C	-f ° ii\I	15		50JSCt			‘k	WC&		aSocuer	h.%5	a	fa e	n
	(x1	\6_	36\ gt	x- v.k.			v-fixs		IN	)(AA		bkaAvt‘n3			tCkca
38		Have you		verbally	stated	or	pos	ted	your	op	inion on	social	media	or	online	about
	Ms		Maxwell	or Mr		Epstein?
		O	Yes	)5(No
		O	Not app	licable,	I		have	not		read/seen/heard		about	Mr	Epstein/Ms		Maxwell
38a	If	yes,	when	and	where	did		you	state	or pos	t your op	inion?

Juror ID: {sup}6 -{sup}0¶

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

| 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

Juror ID: 5O¶

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:

Juror D): 6 0¶

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: 5 0¶

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,
superv	isor,		teacher, or	family		member	.)
	❑	Yes (self)		❑	Yes		(friend	or	family member) )(No
49a If	yes,	without	listing	names p		lease	exp	lain:
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,	p lease	exp lain:
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?
			o	Yes					XNo
50a	If yes,	p lease	exp lain:

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 {sup}50 declare under penalty of perjury that the foregoing answers set forth in this Jury Questionnaire are true and correct to the best of my knowledge and belief. I have not discussed my answers with others, or received assistance in completing the questionnaire.¶

Signed this 1f* 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.¶

& 00000< & 00000> & 00000<< & 00000>