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Court filing · Jan. 24, 2022

New York Times letter to Judge Alison Nathan seeking unsealing of juror questionnaires

An attorney of the New York Times asks Judge Alison Nathan to unseal Ghislaine Maxwell's new-trial motion and seated jurors' questionnaires.Machine-written summary

Document EFTA 02838592

The NewYork Times Company

David McCraw Senior Vicc President & Deputy General Counsel

T 212 556 4031

mccrawtinytimcs.com

6208th Avenue New York, NY 10018 nytimes.com

January 24, 2022

VIA EMAIL AND FEDEX

The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007

The motion to unseal the questionnaires of the twelve seated jurors is GRANTED. The motion to unseal the Defendant’s motion for a new trial is moot as the Defendant’s motion for a new trial is docketed at Dkt. No. 613. SO ORDERED.

Re: United States v. Maxwell. No. 20-cr-00330 (AIN) — Unsealing of Defendant’s Motion for a New Trial and Ouestionnaires of Seated Jurors

Dear Judge Nathan:

I write on behalf of The New York Times Company (“The Times”) to request that the Court unseal (a) Defendant’s Motion for a New Trial and accompanying brief and exhibits (Dkt. 580) and (b) the filled-out questionnaires for the twelve seated jurors. These records are subject to both First Amendment and common law rights of access, which set stringent standards for sealing.’ We ask that the Court unseal them, with only those redactions necessary to protect the identities of jurors, to the extent they have not already been disclosed. We also ask that this Court make clear that any subsequent briefs and exhibits filed in conjunction with this motion should not be filed under seal and with only those redactions necessary to protect jurors’ identities.

As the Court knows, both sets of sealed records bear on allegations of juror misconduct. On January 5, 2022, the parties wrote to this Court regarding public statements made by one juror, identified as “Juror 50,” about how his jury room disclosure that he was a victim of sexual assault

The right of access is an affirmative enforceable public right, and it is wellestablished that the press has standing to enforce this right. See, e.g., Globe Newspaper Co. v. Superior Ct. for Norfolk City, 457 U.S. 596, 609 n.25 (1982); Hartford Courant Co. v. Pellegrino, 380 F.3d 83, 91 (2d Cir. 2004).

influenced deliberations. See Dkts. 568-70. When asked about his juror questionnaire, which included a question about whether he had been a victim of sexual abuse, the juror asserted that he “flew through” the questionnaire and did “not recall being asked” this question. Dkt. 568. Defendant filed a motion for a new trial and asked the Court to keep the motion completely under seal until it ruled on the motion. Dkt. 580.

Defendant’s request for secrecy is contrary to both the common law and the First Amendment.

The Common Law Right of Access

The common law presumption of access attaches to any “judicial document,” defined as items “relevant to the performance of judicial function and useful in the judicial process.” United States v. Amodeo (“Amodeo I”), 44 F.3d 141, 145 (2d Cir. 1995). The presumption is strongest when, as here, documents contribute materially to the Article III powers of the court—that is, to the rendering of verdicts and orders affecting “substantive legal rights.” Lugosch v. Pyramid Co. v. Onondaga, 435 F.3d 110, 121 (2d Cir. 2006). Once the right attaches, it is overcome only by a showing that there are “countervailing factors” that outweigh the public’s right to monitor judicial proceedings.

Defendant’s Motion for New Trial. There is no question that Defendant’s motion, which will directly inform the Court’s assessment of whether a new trial is necessary, is a “judicial document.” See Bernstein v. Bernstein Litowitz Berger & Grossman LLP, 814 F.3d 132, 140, 142 (2d Cir. 2016). Because the motion will be used to determine the parties’ “substantive legal rights,” the presumptive right of access it at its highest. Id.

We do not see anything on the public record indicating that Defendant has met—or tried to meet—the high showing required to justify a blanket sealing of its motion. It is simply not plausible that every word of a legal filing such as this one requires total secrecy. To the extent that the motion contains any sensitive information, there is a reasonable alternative to wholesale sealing: limited redactions of personally identifiable or sensitive information, if justified under the Lugosch standard. See Amodeo I, 44 F.3d at 147.

The right to public access promises “immediate” and “contemporaneous” access. Lugosch, 435 F.3d at 126. The Second Circuit has firmly held that access does not—and should not—hinge on whether a judge has ruled on the underlying motion. Id. at 126–27. Instead, delay is “effectively a denial” and undermines the benefits of public scrutiny. Id. at 126. In Lugosch, the Second Circuit rejected a request to delay access to pending summary judgment papers. So, too, here Defendant’s request for a delay should be denied.

Juror Questionnaires. The juror questionnaires are judicial documents because they are relevant and useful to the performance of a judicial function: selecting a jury, a necessary component of a criminal trial. Here, the presumptive right to access to these questionnaires is at its apex. In effect, the sealing of the questionnaires is the equivalent of barring the public from the oral voir dire. Defendant’s motion requests a new trial because of alleged juror misconduct—and specifically, that “a juror failed to answer honestly a material question on voir dire.” Dkt. 570. Juror 50’s questionnaires will thus, as Defendant recognizes, id., necessarily and directly affect the Court’s decision on whether the existing finding of guilt should be vacated and whether a new trial is appropriate—fundamental Article III determinations. See Amodeo I, 44 F.3d at 145. The questionnaires for the remaining seated jurors are integral to determining whether this is a lone or recurring incident.

Any original need for sealing the questionnaires for the seated jurors—for instance, that they might be subject to attempts to influence their deliberations—has now passed. The trial is over, and the jurors have been dismissed.

The First Amendment Right of Access

An independent First Amendment right of access attaches where public access to a document has historically been available (the “experience” prong) and would be valuable to the process in question (the “logic” prong). See Press-Enter. Co. v. Superior Ct. of Cal. (“Press-Enterprise IF”), 478 U.S. 1, 8–9 (1986); Lugosch, 435 F.3d at 119–20. Once the right attaches, it is overcome only by specific, on-the-record findings that sealing “is essential to preserve higher values and is narrowly tailored to

serve that interest” under the First Amendment. Bernstein, 814 F.3d at 143-45; see also Press-Enterprise II, 478 U.S. at 13-14.

Defendant’s Motion for New Trial. Parties’ motions, briefs, and accompanying exhibits related to post-trial proceedings have regularly been found to be subject to the constitutional right of access, especially when the involve allegations of jury misconduct. See, e.g., United States v. 14 F.3d 833, 840 (3d Cir. 1994); United States v. 927 F. Supp. 768, 782 (D. Del. 1996); see also CBS, Inc. v. U.S. Dist. Ct. for Cent. Dist of Cal., 765 F.2d 823, 825 (9th Cir. 1985). As with the common law right, the constitutional right guarantees “immediate access where a right of access has been found.” Lugosch, 435 F.3d at 126. “[E]ach passing day may constitute a separate and cognizable infringement of the First Amendment” and “unquestionably constitutes irreparable injury.” Id. (internal citations omitted). For the reasons above, Defendant’s motion should be unsealed immediately.

Juror Questionnaires. Juror questionnaires have also regularly been found to be subject to the First Amendment right of access. See United States v. M, 140 F.3d 76, 80, 84 (2d Cir. 1998); United States v.=, 14 F.3d 833, 840 (2d Cir. 1994); United States v. McDade, 929 F. Supp. 815, 817 n.4 (E.D. Pa. 1996); In re Newsday. Inc., 159 A.D.2d 667, 669 (N.Y. App. Div. 1990). As explained above, neither party has proposed on the record that there is any interest of any sort to overcome the presumption. Because the First Amendment’s standards for sealing are even more stringent, the lack of justification for sealing under the common law standard necessarily means that the First Amendment standard has not been met.

It also bears mentioning that the public interest in unsealing these documents is significant. The question immediately before the Court whether a new trial should be granted to a high-profile defendant in light of statements made by a juror that Defendant alleges are evidence of juror misconduct—is serious and goes to the heart of this Court’s Article III judicial power. The documents bear directly on not only “the manner in which criminal trials are conducted,” the aspect of government of highest concern and importance, Richmond Newspaper, Inc. v. Virginia, 448 U.S. 555, 575 (1980), but also specifically voir dire, a central component of a criminal trial—both “to the adversaries [and] to the criminal justice system,” Press-Enter. Co. v. Superior Ct. of Cal. (“Press-Enterprise T’),

464 U.S. 501, 505 (1984). Public scrutiny is essential to “enhance() the quality and safeguard() the integrity” of criminal trials. Globe Newspaper Co. v. Superior a for Norfolk City, 457 U.S. 596, 606 (1982). Openness preserves and is essential to “public confidence in the administration of justice.” ABC, Inc. v. Stewart, 360 F.3d 90, 98 (2d Cir. 2004).

Accordingly, we respectfully ask that the Court unseal Defendant’s Motion for a New Trial and the questionnaires for the twelve seated jurors. We also respectfully ask this Court to make clear that all subsequent documents filed related to this motion should be filed without sealing and with only the redactions necessary to adequately protect the safety of jurors and their identities. We thank the Court for its attention to this matter.

Respectfully submitted,

2

David E. McCraw

cc: All counsel of record (via e-mail)

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 enoug{sup}h information about each juror’s background and experiences to select afair and impartial jury.

Please answer all questions to the best of your ability. If you do not know the answer to {sup}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 a reasonable doubt.

The charges in the Indictment stem from allegations that from at least 1994 through 2004, the Defendant conspired with and aided and abetted Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity, to transport minors to engage in criminal sexual activity, and to engage in sex trafficking of a minor.

The Indictment charges the Defendant in 6 counts: Count One of the Indictment charges the Defendant with conspiring with Jeffrey Epstein and others to entice minors to travel to engage in sexual activity for which a person can be charged with a criminal offense. Count Two charges the Defendant with enticing a minor to travel to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Three charges the Defendant with conspiring with Epstein and others to transport minors to engage in sexual activity for which a person can be charged with a criminal offense. Count Four charges the Defendant with transporting a minor to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Five charges the Defendant with participating in a sex trafficking conspiracy. Count Six charges the Defendant with sex trafficking of a minor, and aiding and abetting the same.

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

SCHEDULE

Potential jurors will be called back for further questioning and jury selection from Tuesday, November 16, 2021, through Friday, November 19, 2021. Your availability during that week will be required.

The trial will commence on Monday, November 29, 2021. The trial is expected to last about six weeks. Generally, trial will be held five days per week, Monday through Friday, from 9:30 a.m. until 5:00 p.m. Trial will not be held on Friday, December 24, 2021 (Christmas Eve Day) and Friday, December 31, 2021 (New Year’s Eve).

If you are selected as a juror, you will be required to be present for the taking of testimony and evidence for as long as the trial lasts. There are no plans to sequester the jury, which means you will go home every day after court.

All jury service involves some degree of hardship. Our court and justice system depends on citizens doing their civic duty to serve as jurors, which involves temporarily putting aside their regular business for jury service. The Court views service on a jury to be one of the highest duties a citizen owes to the United States. Mere inconvenience or the usual financial hardship of jury service will not be sufficient to excuse a prospective juror. You must show extraordinary personal or financial hardship to be excused from service.

Juror D):

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? o Yes a’No

1 a. 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):

neRatfaCtataff tt ti(404/4113ti)

  1. Do you have any unmovable commitments between November 29, 2021, and approximately January 15, 2022, which is the estimated length for trial? o Yes a/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):

:13:Lren - liglafil

  1. Do you have any international travel plans between now and November 29, 2021? o Yes rii/No

  2. Do any circumstances exist such that serving on the jury in this case would entail serious hardship or extreme inconvenience? o Yes /No

4a. If yes, please briefly describe the serious hardship or extreme inconvenience: n ashirA noia

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.:

Do you have any personal commitments that would make it difficult for you 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.

Do you have any personal commitments that would make it difficult for you to get to court by 9:30 a.m. or remain until 5:00 p.m.?



_____

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:

Do you have any personal commitments that would make it difficult for you to get to court by 9:30 a.m. or remain until 5:00 p.m.?



_____

9.Do you have any religious, philosophical, or other beliefs that would make you
o Yes frislo

| ------------------------------------------------------ | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 10. |

Under the law, the facts are for the jury to determine and the law is for the Judge to determine. You are required to accept the law as the Judge explains it to you even if you do not like the law or disagree with it, and you must determine the facts according to those instructions. Do you accept this principle, and will you be able to follow the Judge’s instructions if selected to serve on this jury?

Yes No

| | 10a. |

If no, please explain:

| | 11. |

The law provides that a defendant in a criminal case is presumed innocent at all stages of the trial and is not required to put on any defense at all. The Government is required to prove the defendant guilty beyond a reasonable doubt on each charge. Do you accept these principles, and will you be able to apply them if selected to serve on this jury?

Yes No

| | 11a. |

If no, please explain:

|

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 bear testimony in this case that law enforcement officers recovered certain
o Yes frfro
15a.If yes, please explain:
16.You also may hear testimony in this case from expert witnesses. Have you had any
o Yes rgo
17.As instructed above, from now and until your jury service is complete, you are
o Yes po

| 17a. | If yes, please explain: |

| ----- | ----------------------------------------------------------------------------------- | | 18. | Have you ever served as a juror in a trial in any court? | | | pAtes o No | | 19. | Have you ever at any time served as a member of a grand jury, whether in federal, | | | o Yes tg/glo |

EXPERIENCE AS A WITNESS, DEFENDANT, OR CRIME VICTIM
20.

Have you, or has any relative or close friend, ever participated in a state or federal court case, whether criminal or civil, as a witness, plaintiff, or defendant?

Yes (self)                      Yes (friend or family member)                      No

20a.

If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case?

Yes                                  No

20b.

If yes to 20a, please explain:

21.

Have you or any relative or close friend ever been involved or appeared as a witness in any investigation by a federal or state grand jury or by a congressional or state legislative committee, licensing authority, or governmental agency, or been questioned in any matter by any federal, state, or local law enforcement agency?

Yes (self)                      Yes (friend or family member)                      No

21a.If yes, is there anything about that experience that would prevent you from acting as
❑ Yes it/fin
21b.If yes to 21a, please explain:
22.Have you, or has any relative or close friend, ever been subpoenaed for any inquiry
❑ Yes (self) a Yes (friend or family member) trgo
22a.If yes, is there anything about that experience that would prevent you from acting as
22b.If yes to 22a, please explain:
23.Have you, or has any relative or close friend, ever been arrested or charged with a
❑ Yes (self) o Yes (friend or family member) (t/<:o
23a.If yes, is there anything about that experience that would prevent you from acting as
a Yes e’ No
24.Have you, or has any relative or close friend, ever been the subject of any
o Yes (self) o Yes (friend or family member) b%0
24a.If yes, is there anything about that experience that would prevent you from acting as
o Yes gyKo
24b.If yes to 24a, please explain:
25.Have you, or any of your relatives or close friends, ever been a victim of a crime?
o Yes (self) o Yes (friend or family member) 12’ 20
25a.If yes, is there anything about that experience that would prevent you from acting as
o Yes 0/43
26.Have you, or has any member of your family or any of your close friends—either as
o Yes (self) o Yes (friend or family member) tNo
26a.If yes, is there anything about that experience that would prevent you from acting as
o Yes ao
26b.If yes to 26a, please explain:
27.Have you, or has any member of your family, ever had a dispute concerning money
o Yes (self) a Yes (friend or family member) tato
27a.If yes, is there anything about that experience that would prevent you from acting as
o Yes it J o

| ------ | ------------------------------------------------------------------------------------------------------------------------ | | 28. | Do you or any member of your family or a close friend work in law, law enforcement, the justice system, or the courts? | | | o Yes IAO |

28b.If yes to 28, would this affect your ability to serve as a fair and impartial juror in
o Yes 040
28c.If yes to 28b, please explain:
29.Do you know or have any association—professional, business, or social, direct or
o Yes p’<o
2%.If yes, please explain:
29b.If yes to 29, would this affect your ability to serve as a fair and impartial juror in
o Yes rAo
29c.If yes to 29b, please explain:
30.Do you know or have any association—professional, business, or social, direct or
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
PERSONAL RELATIONSHIP WITH CASE PARTICIPANTS
33.The next subset of questions asks whether you or any member of your family or a close friend personally knows or has past or present dealings with individuals involved in this case. To “personally know” means to have some direct or personal knowledge or connection to the following individuals. If you have only heard the names through media or social media, for example, that is not personal knowledge.
33a.Do you or does any member of your family or a close friend personally know or have past or present dealings with the Defendant in this case, Ghislaine Maxwell, or her family members?

Yes No
33b.Do you or does any member of your family or a close friend personally know or have past or present dealings with Jeffrey Epstein?

Yes No
33c.Do you or does any member of your family or a close friend personally know or have past or present dealings with the U.S. Attorney for the Southern District of New York, Damian [REDACTED] the former Acting U.S. Attorney for the Southern District of New York, Audrey Strauss, or anyone else who works for or used to work for the U.S. Attorney’s Office for the Southern District of New York?

Yes No
33d.Do you or does any member of your family or a close friend personally know or have past or present dealings with any of the Assistant United States Attorneys who are prosecuting this case:

Maurene Comey Yes No
Alison Moe Yes No
Lara Pomerantz Yes No
Andrew Rohrbach Yes No

Juror ID: 4.)

33e. Do you or does any member of your family or a close friend personallyknow or
Christian Everdell of UM& Gresser LLPo Yes cs/go
Jeffrey Pagliuca of Haddon, andP.C. o Yes frit
Laura Menninger of Haddon, andP.C. o Yes 12410
Bobbi Sternheim of Law Offices of Bobbi C. Stemheim o Yeswfsio
33f. Do you or does any member of your family or a close friend personallyknow or
o Yesdo
33g. If you answered “yes” to any of the above sub-questions (33a, 33b, 33; 33d, 33e,

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

This case has been widely reported in the national and local media. There is nothing wrong with having heard something about this case. It is important to answer all of the following questions truthfully and fully.

| | 34. |

Before today, had you read, seen, or heard anything about Ms. Maxwell?

Yes      No      Unsure

| | 34a. |

If yes or unsure, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website, social media). If you heard about Ms. Maxwell from a media source, please identify the media source by name:

Channel 2 news

| | 35. |

Have you personally formed an opinion about Ms. Maxwell’s guilt or innocence of the crimes charged as a result of anything you have heard, read or seen?

Yes      No      Unsure

Not applicable, I have not read/seen/heard about Ms. Maxwell

| | 35a. |

If yes or unsure, please summarize your opinion:

_____

|

36.Based on anything that you have read, seen, or heard about Ms. Maxwell, including
a Yes TA a Unsure
36a.If yes or unsure, please explain why it might be difficult for you to be a fir and
37.Before today, had you read, seen, or heard anything about Jeffrey Epstein?
pAies o No o Unsure
37a.If yes or unsure, please state what you remember hearing, and how or from whom
CiA4 NO Q tutan5 NL
38.Have you verbally stated or posted your opinion on social media or online about
• Yes 5)4o
38a.If yes, when and where did you state or post your opinion?
39.Based on anything that you have read, seen, or heard about Jeffrey Epstein, have
a Yes a° a Unsure
39a.If yes or unsure, please explain why it might be difficult for you to be a fair and
40.If you have heard about Jeffrey Epstein, do you think Ms. Maxwell’s alleged
a Yes ID ❑ Unsure
41.Based on anything you have read, seen, or heard about Ms. Maxwell, including
kr es o No ❑ Unsure

| ------ | ----------------------------------------------------------------------------------------------------------------------------------------- | | 42. | During the trial, you will hear evidence alleging sex crimes against underage girls. you to be a fair and impartial juror in this case? | | | o Yes (r/(o | | 42a. | If yes, please explain: | | 43. | Do you have any specific views or feelings concerning laws regarding the age at | | | o Yes p4o | | 44. | Do you have any opinion about the enforcement of the federal sex trafficking laws from being fair and impartial in this case? | | | o Yes dr‘ |

| ------ | ------------------------------------------------------------------------------------- | | 45. | Have you or a family member ever supported, lobbied, petitioned, protested, or | | | o Yes le4o | | 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 | | | o Yes tvl(o | | 45c. | If yes to 45b, please explain: | | 46. | The witnesses in this case may include law enforcement witnesses. Would you have | | | a Yes dA o |

Juror ID: 9’

47.Witnesses in this case may testify claiming sexual abuse or sexual assault. Would
o Yes tvi)
47a.If yes, please explain:
48.Have you or a friend or family member ever been the victim of sexual harassment,
o Yes (self) o Yes (friend or family member) 04o
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
o Yes ct4o
49.Have you or a friend or family member ever been accused of sexual harassment,
o Yes (self) a Yes (friend or family member) t4o
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
o Yes p4
49c.If yes to 49b, please explain:
50.Is there any other experience that you or anyone close to you has had that may
o Yes to4o

| ------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 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 Q 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 9 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.

Juror ID: 9 \

Juror ID: 9)

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 a reasonable doubt.

The charges in the Indictment stem from allegations that from at least 1994 through 2004, the Defendant conspired with and aided and abetted Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity, to transport minors to engage in criminal sexual activity, and to engage in sex trafficking of a minor.

The Indictment charges the Defendant in 6 counts: Count One of the Indictment charges the Defendant with conspiring with Jeffrey Epstein and others to entice minors to travel to engage in sexual activity for which a person can be charged with a criminal offense. Count Two charges the Defendant with enticing a minor to travel to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Three charges the Defendant with conspiring with Epstein and others to transport minors to engage in sexual activity for which a person can be charged with a criminal offense. Count Four charges the Defendant with transporting a minor to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Five charges the Defendant with participating in a sex trafficking conspiracy. Count Six charges the Defendant with sex trafficking of a minor, and aiding and abetting the same.

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

SCHEDULE

Potential jurors will be called back for further questioning and jury selection from Tuesday, November 16, 2021, through Friday, November 19, 2021. Your availability during that week will be required.

The trial will commence on Monday, November 29, 2021. The trial is expected to last about six weeks. Generally, trial will be held five days per week, Monday through Friday, from 9:30 a.m. until 5:00 p.m. Trial will not be held on Friday, December 24, 2021 (Christmas Eve Day) and Friday, December 31, 2021 (New Year’s Eve).

If you are selected as a juror, you will be required to be present for the taking of testimony and evidence for as long as the trial lasts. There are no plans to sequester the jury, which means you will go home every clay 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.

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

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:

_____

|

Juror Ill: - 1

5.Do you have any personal commitments that would make it difficult for you to get
o Yes )4 No
5a.If yes, please explain why you would be unable to get to court by 9:30 a.m. or
6.Do you have any difficulty reading, speaking, or understanding English?
7.Do you have any medical, physical, or mental condition or illness that makes you
o Yes )4 No
7a.If yes, please briefly describe the condition or illness. If you believe you could serve
8.Are you taking any medication which would prevent you from giving full attention
o Yes *No
9.Do you have any religious, philosophical, or other beliefs that would make you
o Yes is, No
10.Under the law, the facts are for the jury to determine and the law is for the Judge to
)(Yes o No
10a.If no, please explain:
11.The law provides that a defendant in a criminal case is presumed innocent at all serve on this jury?
)1( Yes o No i
11 a.If no, please explain:
12.The law provides that a defendant in a criminal case has an absolute right not to
)(Yes o No
12a.If no, please explain:
13.A juror is required by law to make his or her decision based solely on the evidence
K Yes a No
13a.If no, please explain:
14.Under the law, the question of punishment is for the Court alone to decide, and thus
* Yes a No
15.You may hear testimony in this case that law enforcement officers recovered certain
15a.If yes, please explain:
16.You also may hear testimony in this case from expert witnesses. Have you had any
I6a.If yes, please explain:
17.As instructed above, from now and until your jury service is complete, you are
❑ Yes XNo
17a.If yes, please explain:




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

| --------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 18. |

Have you ever served as a juror in a trial in any court?

Yes No

| | 19. |

Have you ever at any time served as a member of a grand jury, whether in federal, state, county, or city court?

Yes No

|

EXPERIENCEASA WITNESS,DEFENDANT,ORCRIMEVICTIM
20Haveyou,orhasany relativeorclosefriend,everparticipatedinastateor federal
courtcase,whethercriminalor civil,asa witness,p laintiff,or defendant?
o Yes(self)oYes(friendorfamilymember)•jitNo
20aIf yes,isthereanythingaboutthatexperiencethatwouldprevent youfromacting as
a fairandimpartialjurorin thiscase?
❑ Yeso No
20bIf yesto20a,p leaseexplain:
21Haveyouoranyrelativeorclosefriendeverbeeninvolvedor appearedasa witness
in anyinvestigationbya federalor stategrand juryorby acongressionalorstate
legislativecommittee,licensingauthority,orgovernmentalagency,orbeen
questionedinanymatterbyanyfederal,state,orlocallawenforcementagency?
o Yes(self)oYes(friendorfamilymember))(No
21a.If yes, is there anything about that experience that would prevent you from acting as
216.If yes to 21a, please explain:
22.Have you, or has any relative or close friend, ever been subpoenaed for any inquiry
a Yes (self) a Yes (friend or family member) 41 No
22a.If yes, is there anything about that experience that would prevent you from acting as
22b.If yes to 22a, please explain:
23.Have you, or has any relative or close friend, ever been arrested or charged with a
o Yes (self) o Yes (friend or family member) )r( No
23a.If yes, is there anything about that experience that would prevent you from acting as
a Yes a No
24.

Have you, or has any relative or close friend, ever been the subject of any investigation or accusation by any grand jury, state or federal, or any other investigation?

Yes (self)                      Yes (friend or family member)                      No

24a.

If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case?

Yes                                  No

24b.

If yes to 24a, please explain:

_____
_____
_____
_____

25.

Have you, or any of your relatives or close friends, ever been a victim of a crime?

Yes (self)                      Yes (friend or family member)                      No

25a.

If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case?

Yes                                  No

25b.

If yes to 25a, please explain:

_____
_____
_____
_____

26.

Have you, or has any member of your family or any of your close friends—either as individuals or in the course of their business affairs—ever been a party to a legal action or dispute with the United States, or with any of the officers, departments, agencies, or employees of the United States, including the United States Attorney’s Office, the FBI, or the NYPD?

Yes (self)                      Yes (friend or family member)

26a.If yes, is there anything about that experience that would prevent you from acting as
26b.If yes to 26a, please explain:
27.Have you, or has any member of your family, ever had a dispute concerning money
o Yes (self) o Yes (friend or family member) $ No
27a.If yes, is there anything about that experience that would prevent you from acting as
o Yes ci No
RELATIONSHIP WITH, AND VIEW OF, GOVERNMENT, DEFENSE, AND OTHERS
28.Do you or any member of your family or a close friend work in law, law enforcement, the justice system, or the courts?
Yes No
28a.If yes, please explain:
MOTHER, [REDACTED] ADMIN SUPERVISOR


_____
28b.If yes to 28, would this affect your ability to serve as a fair and impartial juror in
o Yes $No
28c.’ If yes to 28b, please explain:
29.Do you know or have any association—professional, business, or social, direct or
29a.If yes, please explain:
29b.If yes to 29, would this affect your ability to serve as a fair and impartial juror in
2%.If yes to 29b, please explain:
30.Do you know or have any association—professional, business, or social, direct or
o Yes $No
30b.If yes to 30, would this affect your ability to serve as a fair and impartial juror in this case?
Yes No
30c.If yes to 30b, please explain:



31.Do you know or have any association—professional, business, or social, direct or indirect—with the New York City Police Department, commonly known as the NYPD?
Yes No
31a.If yes, please explain:
MOTHER, [REDACTED] ADMIN



31b.If yes to 31, would this affect your ability to serve as a fair and impartial juror in this case?
Yes No
31c.If yes to 31b, please explain:



32.Do you have any opinion of the U.S. Attorney’s Office for the Southern District of New York, the U.S. Attorney Damian [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 II): 1

32a.If yes, please explain:




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

| ----------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 33. | The next subset of questions asks whether you or any member of your family or a close friend personally knows or has past or present dealings with individuals involved in this case. To “personally know” means to have some direct or personal knowledge or connection to the following individuals. If you have only heard the names through media or social media, for example, that is not personal knowledge. | | 33a. | Do you or does any member of your family or a close friend personally know or have past or present dealings with the Defendant in this case, Ghislaine Maxwell, or her family members?

Yes No | | 33b. | Do you or does any member of your family or a close friend personally know or have past or present dealings with Jeffrey Epstein?

Yes No | | 33c. | Do you or does any member of your family or a close friend personally know or have past or present dealings with the U.S. Attorney for the Southern District of New York, Damian [REDACTED] the former Acting U.S. Attorney for the Southern District of New York, Audrey Strauss, or anyone else who works for or used to work for the U.S. Attorney’s Office for the Southern District of New York?

Yes No | | 33d. | Do you or does any member of your family or a close friend personally know or have past or present dealings with any of the Assistant United States Attorneys who are prosecuting this case:

Maurene Comey Yes No
Alison Moe Yes No
Lara Pomerantz Yes No
Andrew Rohrbach Yes No |

33e.Do you or does any member of your family or a close friend personallyknow or
Christian Everdell of etcGreaser LLP o Yes No
Jeffrey Pagliuca of Haddon, andlEM P.C. o Yes No
Laura Menninger of Haddon, and1.= P.C. o Yes )( No
33f.Do you or does any member of your family or a close friend personallyknow or
o YesX. No
33g.If you answered “yes” to any of the above sub-questions (33a, 33b, 33c, 33d, 33e,
KNOWLEDGE OF CASE AND PEOPLE
34.Before today, had you read, seen, or heard anything about
I Yes XNo o Unsure
34a.If yes or unsure, please state what you remember hearing, and how or from whom name:
35.Have you personally formed an opinion about Ms. Maxwell’s guilt or innocence of
o Yes o No o Unsure
35a.If yes or unsure, please summarize your opinion:
36.

Based on anything that you have read, seen, or heard about Ms. Maxwell, including anything about criminal charges against Ms. Maxwell, have you formed any opinions about Ms. Maxwell that might make it difficult for you to be a fair and impartial juror in this case?

Yes      No      Unsure

Not applicable, I have not read/seen/heard about Ms. Maxwell

36a.

If yes or unsure, please explain why it might be difficult for you to be a fair and impartial juror in this case:

37.

Before today, had you read, seen, or heard anything about Jeffrey Epstein?

Yes      No      Unsure

37a.

If yes or unsure, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website, social media). If you heard about Mr. Epstein from a media source, please identify the media source by name:

HE PASSED AWAY IN PRISON

_____

38.

Have you verbally stated or posted your opinion on social media or online about Ms. Maxwell or Mr. Epstein?

Yes      No

Not applicable, I have not read/seen/heard about Mr. Epstein/Ms. Maxwell

38a.

If yes, when and where did you state or post your opinion?

39.Based on anything that you have read, seen, or heard about Jeffrey Epstein, have
o Yes No o Unsure
39a.If yes or unsure, please explain why it might be difficult for you to be a fair and
40.If you have heard about Jeffrey Epstein, do you think Ms. Maxwell’s alleged
o Yes $No o Unsure
41.Based on anything you have read, seen, or heard about Ms. Maxwell, including
o Yes o No a Unsure
Y t. Not applicable, I have not read/seen/heard about Ms. Maxwell

| ------ | ----------------------------------------------------------------------------------------------------------------------------------------- | | 42. | During the trial, you will hear evidence alleging sex crimes against underage girls. you to be a fair and impartial juror in this case? | | | o Yes XNo | | 42a. | If yes, please explain: | | 43. | Do you have any specific views or feelings concerning laws regarding the age at | | | o Yes 4o | | 44. | Do you have any opinion about the enforcement of the federal sex trafficking laws from being fair and impartial in this case? |

Juror II):

| ------ | ------------------------------------------------------------------------------------- | | 45. | Have you or a family member ever supported, lobbied, petitioned, protested, or | | | o Yes XNo | | 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 | | 45c. | If yes to 45b, please explain: | | 46. | The witnesses in this case may include law enforcement witnesses. Would you have |

47.Witnesses in this case may testify claiming sexual abuse or sexual assault. Would
47a.If yes, please explain:
48.Have you or a friend or family member ever been the victim of sexual harassment,
a Yes (self) a Yes (friend or family member) \A 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
49.Have you or a friend or family member ever been accused of sexual harassment,
o Yes (self) o Yes (friend or family member) \ k 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
o Yes a 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
o Yes ›[No

| ------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 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):




|

JurorlD: —1

DECLARATION

I, Juror Number 1 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 A II I 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.

Juror ID: —1

JurorID: —1

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 a reasonable doubt.

The charges in the Indictment stem from allegations that from at least 1994 through 2004, the Defendant conspired with and aided and abetted Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity, to transport minors to engage in criminal sexual activity, and to engage in sex trafficking of a minor.

The Indictment charges the Defendant in 6 counts: Count One of the Indictment charges the Defendant with conspiring with Jeffrey Epstein and others to entice minors to travel to engage in sexual activity for which a person can be charged with a criminal offense. Count Two charges the Defendant with enticing a minor to travel to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Three charges the Defendant with conspiring with Epstein and others to transport minors to engage in sexual activity for which a person can be charged with a criminal offense. Count Four charges the Defendant with transporting a minor to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Five charges the Defendant with participating in a sex trafficking conspiracy. Count Six charges the Defendant with sex trafficking of a minor, and aiding and abetting the same.

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

SCHEDULE

Potential jurors will be called back for further questioning and jury selection from Tuesday, November 16, 2021, through Friday, November 19, 2021. Your availability during that week will be required.

The trial will commence on Monday, November 29, 2021. The trial is expected to last about six weeks. Generally, trial will be held five days per week, Monday through Friday, from 9:30 a.m. until 5:00 p.m. Trial will not be held on Friday, December 24, 2021 (Christmas Eve Day) and Friday, December 31, 2021 (New Year’s Eve).

If you are selected as a juror, you will be required to be present for the taking of testimony and evidence for as long as the trial lasts. There are no plans to sequester the jury, which means you will go home every day after court.

All jury service involves some degree of hardship. Our court and justice system depends on citizens doing their civic duty to serve as jurors, which involves temporarily putting aside their regular business for jury service. The Court views service on a jury to be one of the highest duties a citizen owes to the United States. Mere inconvenience or the usual financial hardship of jury service will not be sufficient to excuse a prospective juror. You must show extraordinary personal or £mania! hardship to be excused from service.

PLEASE ANSWER THE FOLLOWING QUESTIONS:

| ------ | ------------------------------------------------------------------------------------------------------------------------------- | | 1. | Do you have any unmovable commitments between November 16, 2021, and | | | a Yes /No | | I a. | If yes, please explain (without indicating the name of where you work or the names who you are): | | 2. | Do you have any unmovable commitments between November 29, 2021, and | | | o Yes “(No | | 2a. | If yes, please explain (without indicating the name of where you work or the names who you are): | | 3. | Do you have any international travel plans between now and November 29, 2021? | | | a Yes a4lo | | 4. | Do any circumstances exist such that serving on the jury in this case would entail serious hardship or extreme inconvenience? | | | o Yes jeNo | | 4a. | If yes, please briefly describe the serious hardship or extreme inconvenience: |

Juror ID: 4’

5.Do you have any personal commitments that would make it difficult for you to get
o Yes / cr No
5a.If yes, please explain why you would be unable to get to court by 9:30 a.m. or
6.Do you have any difficulty reading, speaking, or understanding English?
a Yes ,z(No
7.Do you have any medical, physical, or mental condition or illness that makes you
o Yes “(No
7a.If yes, please briefly describe the condition or illness. If you believe you could serve
8.Are you taking any medication which would prevent you from giving full attention
o Yes %No

Juror ID: 2-4-

9.Do you have any religious, philosophical, or other beliefs that would make you
0 Yes ,e 1No
10.Under the law, the facts are for the jury to determine and the law is for the Judge to
ArYes o No
10a.If no, please explain:
11.The law provides that a defendant in a criminal case is presumed innocent at all serve on this jury?
ja/Yes o No
1 I a.If no, please explain:
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
o Yes a’o
15a.If yes, please explain:
16.You also may hear testimony in this case from expert witnesses. Have you had any
o Yes eja’No
17.As instructed above, from now and until your jury service is complete, you are
a Yes yisio
17a.If yes, please explain:




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

| ----- | ----------------------------------------------------------------------------------------------------------------- | | 18. | Have you ever served as a juror in a trial in any court? | | | „Er Yes o No | | 19. | Have you ever at any time served as a member of a grand jury, whether in federal, state, county, or city court? | | | a Yes ,te No |

EXPERIENCE AS A WITNESS, DEFENDANT, OR CRIME VICTIM
20.

Have you, or has any relative or close friend, ever participated in a state or federal court case, whether criminal or civil, as a witness, plaintiff, or defendant?

Yes (self)                      Yes (friend or family member)                      No

20a.

If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case?

Yes                      No

20b.

If yes to 20a, please explain:





21.

Have you or any relative or close friend ever been involved or appeared as a witness in any investigation by a federal or state grand jury or by a congressional or state legislative committee, licensing authority, or governmental agency, or been questioned in any matter by any federal, state, or local law enforcement agency?

Yes (self)                      Yes (friend or family member)                      No

21a.If yes, is there anything about that experience that would prevent you from acting as
21b.If yes to 21; please explain:
22.Have you, or has any relative or close friend, ever been subpoenaed for any inquiry
a Yes (self) o Yes (friend or family member) pr41O
22a.If yes, is there anything about that experience that would prevent you from acting as
22b.If yes to 22a, please explain:
23.Have you, or has any relative or close friend, ever been arrested or charged with a
o Yes (self) o Yes (friend or family member) ,e’No
23a.If yes, is there anything about that experience that would prevent you from acting as

Juror ID: ’:,

24.Have you, or has any relative or close friend, ever been the subject of any
o Yes (self) o Yes (friend or family member) lo
24a.If yes, is there anything about that experience that would prevent you from acting as
24b.If yes to 24a, please explain:
25.Have you, or any of your relatives or close friends, ever been a victim of a crime?
o Yes (self) o Yes (friend or family member) p’No
25a.If yes, is there anything about that experience that would prevent you from acting as
26.Have you, or has any member of your family or any of your close friends—either as
o Yes (self) o Yes (friend or family member) Anslo
26a.If yes, is there anything about that experience that would prevent you from acting as
26b.If yes to 26a, please explain:
27.Have you, or has any member of your family, ever had a dispute concerning money
o Yes (self) o Yes (friend or family member) tNo
27a.If yes, is there anything about that experience that would prevent you from acting as
RELATIONSHIP WITH, AND VIEW OF, GOVERNMENT, DEFENSE, AND OTHERS
28.Do you or any member of your family or a close friend work in law, law enforcement, the justice system, or the courts?
Yes No
28a.If yes, please explain:

I Work for [REDACTED]

as an Admin. Contract Specialist.




Juror ID: .7k

28b.If yes to 28, would this affect your ability to serve as a fair and impartial juror in
o Yes „ho
28c.If yes to 28b, please explain:
29.Do you know or have any association—professional, business, or social, direct or
o 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
29c.If yes to 29b, please explain:
30.Do you know or have any association—professional, business, or social, direct or
o Yes „Erfslo

Juror ID: Z-L.

30b.If yes to 30, would this affect your ability to serve as a fair and impartial juror in this case?

Yes No
30c.If yes to 30b, please explain:




31.Do you know or have any association—professional, business, or social, direct or indirect—with the New York City Police Department, commonly known as the NYPD?

Yes No
31a.If yes, please explain:

I know with [redacted] 95 and Admin. Contract Specialist.


31b.If yes to 31, would this affect your ability to serve as a fair and impartial juror in this case?

Yes No
31c.If yes to 31b, please explain:



_____
32.Do you have any opinion of the U.S. Attorney’s Office for the Southern District of New York, the U.S. Attorney Damian [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 HD: 7c,

PERSONAL RELATIONSHIP WITH CASE PARTICIPANTS
33.The next subset of questions asks whether you or any member of your family or a close friend personally knows or has past or present dealings with individuals involved in this case. To To “personally know” means to have some direct or personal knowledge or connection to the following individuals. If you have only heard the names through media or social media, for example, that is not personal knowledge.
33a.Do you or does any member of your family or a close friend personally know or have past or present dealings with the Defendant in this case, Ghislaine Maxwell, or her family members?

Yes No
33b.Do you or does any member of your family or a close friend personally know or have past or present dealings with Jeffrey Epstein?

Yes No
33c.Do you or does any member of your family or a close friend personally know or have past or present dealings with the U.S. Attorney for the Southern District of New York, Damian [REDACTED], the former Acting U.S. Attorney for the Southern District of New York, Audrey Strauss, or anyone else who works for or used to work for the U.S. Attorney’s Office for the Southern District of New York?

Yes No
33d.Do you or does any member of your family or a close friend personally know or have past or present dealings with any of the Assistant United States Attorneys who are prosecuting this case:

Maurene Comey Yes No
Alison Moe Yes No
Lara Pomerantz Yes No
Andrew Rohrbach Yes No
Maurene Comey Yes NoAlison Moe Yes NoLara Pomerantz Yes NoAndrew Rohrbach Yes No
Maurene Comey Yes No
Alison Moe Yes No
Lara Pomerantz Yes No
Andrew Rohrbach Yes No
33e. Do you or does any member of your family or a close friend personallyknow or
Christian Everdell of MI& Gresser LLPo Yes if No
Jeffrey Pagliuca of Haddon, andP.C. o Yes .VNo
Laura Menninger of Haddon,and P.C. o Yes z No
Bobbi Stemheim of Law Offices of Bobbi C. Stemheim o Yes ot/No
33f. Do you or does any member of your family or a close friend personallyknow or
o Yeso No
33g. If you answered “yes” to any of the above sub-questions (33; 33b, 33c, 33d, 33e,

Juror ID: —Z C

KNOWLEDGE OF CASE AND PEOPLE
34.Before today, had you read, seen, or heard anything about
Yes /No o Unsure
34a.If yes or unsure, please state what you remember hearing, and how or from whom name:
o Yes /No a Unsure
35a.If yes or unsure, please summarize your opinion:

Juror lID:1-eo

36.Based on anything that you have read, seen, or heard about Ms. Maxwell, including anything about criminal charges against Ms. Maxwell, have you formed any opinions about Ms. Maxwell that might make it difficult for you to be a fair and impartial juror in this case?

Yes No Unsure

Not applicable, I have not read/seen/heard about Ms. Maxwell
36a.If yes or unsure, please explain why it might be difficult for you to be a fair and impartial juror in this case:




37.Before today, had you read, seen, or heard anything about Jeffrey Epstein?

Yes No Unsure
37a.If yes or unsure, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website, social media). If you heard about Mr. Epstein from a media source, please identify the media source by name:

I saw on television media that Mr. Epstein was aroused of sex trafficking.




38.Have you verbally stated or posted your opinion on social media or online about Ms. Maxwell or Mr. Epstein?

Yes No

Not applicable, I have not read/seen/heard about Mr. Epstein/Ms. Maxwell
38a.If yes, when and where did you state or post your opinion?




Juror ID: 2-4.

39.Based on anything that you have read, seen, or heard about Jeffrey Epstein, have
o Yes “No o Unsure
39a.If yes or unsure, please explain why it might be difficult for you to be a fair and
40.If you have heard about Jeffrey Epstein, do you think Ms. Maxwell’s alleged
o Yes Alt o Unsure
41.Based on anything you have read, seen, or heard about Ms. Maxwell, including
/Yes ❑ No a Unsure

Juror ID: 2,4-

| ------ | ----------------------------------------------------------------------------------------------------------------------------------------- | | 42. | During the trial, you will hear evidence alleging sex crimes against underage girls. you to be a fair and impartial juror in this case? | | | o Yes .a4Io | | 4Th. | If yes, please explain: | | 43. | Do you have any specific views or feelings concerning laws regarding the age at | | | o Yes XNo | | 44. | Do you have any opinion about the enforcement of the federal sex trafficking laws from being fair and impartial in this case? | | | o Yes /No |

44a.Ifyes, please explain:
45.Have you or a family member ever supported, lobbied, petitioned, protested, or
o 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
o Yes ❑ No
45c.If yes to 45b, please explain:
46.The witnesses in this case may include law enforcement witnesses. Would you have
o Yes /No

Juror ID: 2 to

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:

Zia Juror ID:

49.Have you or a friend or family member ever been accused of sexual harassment,
o Yes (self) a Yes (friend or family member) 7 /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
49c.If yes to 49b, please explain:
50.Is there any other experience that you or anyone close to you has had that may
a Yes et(No

| ------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | | 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):




|

Juror ID: g?” ’”.

DECLARATION

1, Juror Numbera- 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.

Juror ID:” (=’

Juror ID: ,.76

Juror ED: . ---6’

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 a reasonable doubt.

The charges in the Indictment stem from allegations that from at least 1994 through 2004, the Defendant conspired with and aided and abetted Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity, to transport minors to engage in criminal sexual activity, and to engage in sex trafficking of a minor.

The Indictment charges the Defendant in 6 counts: Count One of the Indictment charges the Defendant with conspiring with Jeffrey Epstein and others to entice minors to travel to engage in sexual activity for which a person can be charged with a criminal offense. Count Two charges the Defendant with enticing a minor to travel to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Three charges the Defendant with conspiring with Epstein and others to transport minors to engage in sexual activity for which a person can be charged with a criminal offense. Count Four charges the Defendant with transporting a minor to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Five charges the Defendant with participating in a sex trafficking conspiracy. Count Six charges the Defendant with sex trafficking of a minor, and aiding and abetting the same.

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

Juror ID: Z CI

SCHEDULE

Potential jurors will be called back for further questioning and jury selection from Tuesday, November 16, 2021, through Friday, November 19, 2021. Your availability during that week will be required.

The trial will commence on Monday, November 29, 2021. The trial is expected to last about six weeks. Generally, trial will be held five days per week, Monday through Friday, from 9:30 a.m. until 5:00 p.m. Trial will not be held on Friday, December 24, 2021 (Christmas Eve Day) and Friday, December 31, 2021 (New Year’s Eve).

If you are selected as a juror, you will be required to be present for the taking of testimony and evidence for as long as the trial lasts. There are no plans to sequester the jury, which means you will go home every day after court.

All jury service involves some degree of hardship. Our court and justice system depends on citizens doing their civic duty to serve as jurors, which involves temporarily putting aside their regular business for jury service. The Court views service on a jury to be one of the highest duties a citizen owes to the United States. Mere inconvenience or the usual financial hardship of jury service will not be sufficient to excuse a prospective juror. You must show extraordinary personal or financial hardship to be excused from service.

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

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
o Yes ergo
5a.If yes, please explain why you would be unable to get to court by 9:30 a.m. or
6.Do you have any difficulty reading, speaking, or understanding English?
o Yes e-NO
7.Do you have any medical, physical, or mental condition or illness that makes you
o Yes ta—Ko—
7a.If yes, please briefly describe the condition or illness. If you believe you could serve
8.Are you taking any medication which would prevent you from giving full attention
o Yes ifriC

Juror ID: 2 q

9.

Do you have any religious, philosophical, or other beliefs that would make you unable to render a verdict in a criminal case?

Yes

No

9a.

If yes, please explain:












10.Under the law, the facts are for the jury to determine and the law is for the Judge to
Erics o No
10a.If no, please explain:
11.The law provides that a defendant in a criminal case is presumed innocent at all serve on this jury?
Etes o No
I la.If no, please explain:

Juror ID: 2M

12.The law provides that a defendant in a criminal case has an absolute right not to
uKfes ❑ No
12a.If no, please explain:
13.A juror is required by law to make his or her decision based solely on the evidence
re< ❑ No
I3a.If no, please explain:
14.Under the law, the question of punishment is for the Court alone to decide, and thus
ov’fres ❑ No
I4a.If no, please explain:
15.You may hear testimony in this case that law enforcement officers recovered certain
❑ Yes to ‘
15a.If yes, please explain:
16.You also may hear testimony in this case from expert witnesses. Have you had any
❑ Yes at—‹
I 6a.If yes, please explain:
17.As instructed above, from now and until your jury service is complete, you are
❑ Yes tri(o

Juror ID: 2.

| 17a. | If yes, please explain: _____ |

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

| ----- | ----------------------------------------------------------------------------------------------------------------- | | 18. | Have you ever served as a juror in a trial in any court? o Yes | | 19. | Have you ever at any time served as a member of a grand jury, whether in federal, state, county, or city court? | | | o Yes ,t |

EXPERIENCE AS A WITNESS, DEFENDANT, OR CRIME VICTIM
20.

Have you, or has any relative or close friend, ever participated in a state or federal court case, whether criminal or civil, as a witness, plaintiff, or defendant?

Yes (self) Yes (friend or family member) No
20a.

If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case?

Yes No
20b.

If yes to 20a, please explain:

21.

Have you or any relative or close friend ever been involved or appeared as a witness in any investigation by a federal or state grand jury or by a congressional or state legislative committee, licensing authority, or governmental agency, or been questioned in any matter by any federal, state, or local law enforcement agency?

Yes (self) Yes (friend or family member) No

Juror II): 2 (31

21a.If yes, is there anything about that experience that would prevent you from acting as
21b.If yes to 21a, please explain:
22.Have you, or has any relative or close friend, ever been subpoenaed for any inquiry
teCes (self) o Yes (friend or family member) a No
22a.If yes, is there anything about that experience that would prevent you from acting as
o Yes 4o
22b.If yes to 22a, please explain:
23.Have you, or has any relative or close friend, ever been arrested or charged with a
a Yes (self) o Yes (friend or family member) crioe
23a.If yes, is there anything about that experience that would prevent you from acting as
o Yes a No

Juror ID: 2 S

24.Have you, or has any relative or close friend, ever been the subject of any
o Yes (self) o Yes (friend or family member) crgo -
24a.If yes, is there anything about that experience that would prevent you from acting as
24b.If yes to 24a, please explain:
25.Have you, or any of your relatives or close friends, ever been a victim of a crime?
a Yes (self) o Yes (friend or family member) tog;
25a.If yes, is there anything about that experience that would prevent you from acting as
26.Have you, or has any member of your family or any of your close friends—either as
a Yes (self) a Yes (friend or family member) reg; .

Juror ID: Z q

26a.If yes, is there anything about that experience that would prevent you from acting as
c Yes a No
26b.If yes to 26a, please explain:
27.Have you, or has any member of your family, ever had a dispute concerning money
o Yes (self) a Yes (friend or family member) Elcir
27a.If yes, is there anything about that experience that would prevent you from acting as
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:

Brother in law is a [REDACTED] police officer
28b.If yes to 28, would this affect your ability to serve as a fair and impartial juror in 1
o Yes WIT;
28c.If yes to 28b, please explain:
29.Do you know or have any association—professional, business, or social, direct or
o Yes sr<
29a.If yes, please explain:
29b.If yes to 29, would this affect your ability to serve as a fair and impartial juror in
o Yes a No
29c.If yes to 29b, please explain:
30.Do you know or have any association—professional, business, or social, direct or
o Yes erfC
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:

Brother-in-law works for [REDACTED] [REDACTED] [REDACTED]

_____

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

PERSONAL RELATIONSHIP WITH CASE PARTICIPANTS
33.The next subset of questions asks whether you or any member of your family or a close friend personally knows or has past or present dealings with individuals involved in this case. To “personally know” means to have some direct or personal knowledge or connection to the following individuals. If you have only heard the names through media or social media, for example, that is not personal knowledge.
33a.Do you or does any member of your family or a close friend personally know or have past or present dealings with the Defendant in this case, Ghislaine Maxwell, or her family members?

Yes No
33b.Do you or does any member of your family or a close friend personally know or have past or present dealings with Jeffrey Epstein?

Yes No
33c.Do you or does any member of your family or a close friend personally know or have past or present dealings with the U.S. Attorney for the Southern District of New York, Damian [REDACTED], the former Acting U.S. Attorney for the Southern District of New York, Audrey Strauss, or anyone else who works for or used to work for the U.S. Attorney’s Office for the Southern District of New York?

Yes No
33d.Do you or does any member of your family or a close friend personally know or have past or present dealings with any of the Assistant United States Attorneys who are prosecuting this case:

Maurene Comey Yes No
Alison Moe Yes No
Lara Pomerantz Yes No
Andrew Rohrbach Yes No
33e.Do you or does any member of your family or a close friend personallyknow or
Christian Everdell of& Dresser LLP ❑ Yes m—No
Jeffrey Pagliuca of Haddon,and P.C. a Yes trIcIt
Laura Menninger of Haddon,and P.C. ❑ Yes m—N6
Bobbi Stemheim of Law Offices of Bobbi C. Sternheim❑ Yes c..-146
33f.Do you or does any member of your family or a close friend personallyknow or
❑ Yes
33g.If you answered “yes” to any of the above sub-questions (33a, 33b, 33c, 33d, 33e,

Juror ID: 2q

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

This case has been widely reported in the national and local media. There is nothing wrong with having heard something about this case. It is important to answer all of the following questions truthfully and fully.

| | 34. |

Before today, had you read, seen, or heard anything about Ms. Maxwell?

Yes      No      Unsure

| | 34a. |

If yes or unsure, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website, social media). If you heard about Ms. Maxwell from a media source, please identify the media source by name:

I have heard of this case on TV, but I don’t recall seeing or hearing about Ms. Maxwell, but I am not 100% sure.











| | 35. |

Have you personally formed an opinion about Ms. Maxwell’s guilt or innocence of the crimes charged as a result of anything you have heard, read or seen?

Yes      No      Unsure

Not applicable, I have not read/seen/heard about Ms. Maxwell

| | 35a. |

If yes or unsure, please summarize your opinion:











|

Juror ID: 2,

36.Based on anything that you have read, seen, or heard about Ms. Maxwell, including anything about criminal charges against Ms. Maxwell, have you formed any opinions about Ms. Maxwell that might make it difficult for you to be a fair and impartial juror in this case?
Yes No Unsure

Not applicable, I have not read/seen/heard about Ms. Maxwell
36a.If yes or unsure, please explain why it might be difficult for you to be a fair and impartial juror in this case:





37.Before today, had you read, seen, or heard anything about Jeffrey Epstein?
Yes No Unsure
37a.If yes or unsure, please state what you remember hearing, and how or from whom you may have heard ( e.g. , a friend, the newspaper, a website, social media). If you heard about Mr. Epstein from a media source, please identify the media source by name:

I have heard of Mr. Epstein on CNN and perhaps on ABC/NBC, but not in great details.





38.Have you verbally stated or posted your opinion on social media or online about Ms. Maxwell or Mr. Epstein?
Yes No

Not applicable, I have not read/seen/heard about Mr. Epstein/Ms. Maxwell
38a.If yes, when and where did you state or post your opinion?





39.Based on anything that you have read, seen, or heard about Jeffrey Epstein, have
o Yes irl<> o Unsure
39a.If yes or unsure, please explain why it might be difficult for you to be a fair and
40.If you have heard about Jeffrey Epstein, do you think Ms. Maxwell’s alleged
o Yes trIC o Unsure
41.Based on anything you have read, seen, or heard about Ms. Maxwell, including
wes o No o Unsure

Juror ID: 7- 1

| ------ | ----------------------------------------------------------------------------------------------------------------------------------------------- | | 42. | During the trial, you will hear evidence alleging sex crimes against underage girls. you to be a fair and impartial juror in this case? a Yes | | 42a. | If yes, please explain: | | 43. | Do you have any specific views or feelings concerning laws regarding the age at | | | o Yes bAcir | | 44. | Do you have any opinion about the enforcement of the federal sex trafficking laws from being fair and impartial in this case? | | | ❑ Yes trIC |

Juror ID: 2.9

| ------ | ------------------------------------------------------------------------------------- | | 45. | Have you or a family member ever supported, lobbied, petitioned, protested, or | | | ❑ Yes tr< | | 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 | | 45c. | If yes to 45b, please explain: | | 46. | The witnesses in this case may include law enforcement witnesses. Would you have | | | ❑ Yes Pl‹ : . |

47.Witnesses in this case may testify claiming sexual abuse or sexual assault. Would
o Yes tr<
47a.If yes, please explain:
48.Have you or a friend or family member ever been the victim of sexual harassment,
o Yes (self) o Yes (friend or family member) 04
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

Juror ID: 2 Ci

49.Have you or a friend or family member ever been accused of sexual harassment,
o Yes (self) o Yes (friend or family member) m—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
49c.If yes to 49b, please explain:
50.Is there any other experience that you or anyone close to you has had that may
a Yes ieRT1-

Juror ID: 1,Ci

| ------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 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 2Ci 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 09 day of November, 2021

2 (11

Juror ID: 2. ci

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.

Juror ID: 2 i

Juror ID: 2 °I

Juror ID: 2 QI

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 a reasonable doubt.

The charges in the Indictment stem from allegations that from at least 1994 through 2004, the Defendant conspired with and aided and abetted Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity, to transport minors to engage in criminal sexual activity, and to engage in sex trafficking of a minor.

The Indictment charges the Defendant in 6 counts: Count One of the Indictment charges the Defendant with conspiring with Jeffrey Epstein and others to entice minors to travel to engage in sexual activity for which a person can be charged with a criminal offense. Count Two charges the Defendant with enticing a minor to travel to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Three charges the Defendant with conspiring with Epstein and others to transport minors to engage in sexual activity for which a person can be charged with a criminal offense. Count Four charges the Defendant with transporting a minor to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Five charges the Defendant with participating in a sex trafficking conspiracy. Count Six charges the Defendant with sex trafficking of a minor, and aiding and abetting the same.

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

SCHEDULE

Potential jurors will be called back for further questioning and jury selection from Tuesday, November 16, 2021, through Friday, November 19, 2021. Your availability during that week will be required.

The trial will commence on Monday, November 29, 2021. The trial is expected to last about six weeks. Generally, trial will be held five days per week, Monday through Friday, from 9:30 a.m. until 5:00 p.m. Trial will not be held on Friday, December 24, 2021 (Christmas Eve Day) and Friday, December 31, 2021 (New Year’s Eve).

If you are selected as a juror, you will be required to be present for the taking of testimony and evidence for as long as the trial lasts. There are no plans to sequester the jury, which means you will go home every day after court.

All jury service involves some degree of hardship. Our court and justice system depends on citizens doing their civic duty to serve as jurors, which involves temporarily putting aside their regular business for jury service. The Court views service on a jury to be one of the highest duties a citizen owes to the United States. Mere inconvenience or the usual financial hardship of jury service will not be sufficient to excuse a prospective juror. You must show extraordinary personal or financial hardship to be excused from service.

PLEASE ANSWER THE FOLLOWING QUESTIONS:

| ------ | ------------------------------------------------------------------------------------------------------------------------------- | | 1. | Do you have any unmovable commitments between November 16, 2021, and | | | o Yes O. No | | I a. | If yes, please explain (without indicating the name of where you work or the names who you are): | | 2. | Do you have any unmovable commitments between November 29, 2021, and | | | o Yes cri No | | 2a. | If yes, please explain (without indicating the name of where you work or the names who you are): | | 3. | Do you have any international travel plans between now and November 29, 2021? | | | o Yes a No | | 4. | Do any circumstances exist such that serving on the jury in this case would entail serious hardship or extreme inconvenience? | | | o Yes El 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
❑ Yes g No
5a.If yes, please explain why you would be unable to get to court by 9:30 a.m. or
6.Do you have any difficulty reading, speaking, or understanding English?
❑ Yes 4 No
7.Do you have any medical, physical, or mental condition or illness that makes you
❑ Yes 4 No
7a.If yes, please briefly describe the condition or illness. If you believe you could serve
8.Are you taking any medication which would prevent you from giving full attention
❑ Yes 0 No
9.Do you have any religious, philosophical, or other beliefs that would make you
❑ Yes vi No
10.Under the law, the facts are for the jury to determine and the law is for the Judge to
4g Yes ❑ No
I Oa.If no, please explain:
11.The law provides that a defendant in a criminal case is presumed innocent at all serve on this jury?
sir Yes ❑ No
I la.If no, please explain:
12.The law provides that a defendant in a criminal case has an absolute right not to
git 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
at Yes o No
13a.If no, please explain:
14.Under the law, the question of punishment is for the Court alone to decide, and thus
as, Yes o No
15.You may hear testimony in this case that law enforcement officers recovered certain
❑ Yes ‘RJ No
15a.If yes, please explain:
16.You also may hear testimony in this case from expert witnesses. Have you had any
❑ Yes fit No
17.As instructed above, from now and until your jury service is complete, you are
❑ Yes 4, No

| 17a. | If yes, please explain: _____ |

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

| ----- | ----------------------------------------------------------------------------------- | | 18. | Have you ever served as a juror in a trial in any court? | | | c0( Yes o No | | 19. | Have you ever at any time served as a member of a grand jury, whether in federal, | | | o Yes Aa No |

EXPERIENCE AS A WITNESS, DEFENDANT, OR CRIME VICTIM
20.

Have you, or has any relative or close friend, ever participated in a state or federal court case, whether criminal or civil, as a witness, plaintiff, or defendant?

Yes (self)                      Yes (friend or family member)                      No

20a.

If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case?

Yes                                  No

20b.

If yes to 20a, please explain:

_____
_____
_____
_____

21.

Have you or any relative or close friend ever been involved or appeared as a witness in any investigation by a federal or state grand jury or by a congressional or state legislative committee, licensing authority, or governmental agency, or been questioned in any matter by any federal, state, or local law enforcement agency?

Yes (self)                      Yes (friend or family member)                      No

21a.If yes, is there anything about that experience that would prevent you from acting as
21b.If yes to 21a, please explain:
22.Have you, or has any relative or close friend, ever been subpoenaed for any inquiry
❑ Yes (self) ❑ Yes (friend or family member) K No
22a.If yes, is there anything about that experience that would prevent you from acting as
22b.If yes to 22a, please explain:
23.Have you, or has any relative or close friend, ever been arrested or charged with a
o Yes (self) lic Yes (friend or family member) ❑ No
23a.If yes, is there anything about that experience that would prevent you from acting as
❑ Yes •••3No
24.Have you, or has any relative or close friend, ever been the subject of any
o Yes (self) o Yes (friend or family member) Cr No
24a.If yes, is there anything about that experience that would prevent you from acting as
24b.If yes to 24a, please explain:
25.Have you, or any of your relatives or close friends, ever been a victim of a crime?
o Yes (self) o Yes (friend or family member) v.( No
25a.If yes, is there anything about that experience that would prevent you from acting as
26.Have you, or has any member of your family or any of your close friends—either as
o Yes (self) o Yes (friend or family member) KNo
26a.If yes, is there anything about that experience that would prevent you from acting as
❑ Yes o No
26b.If yes to 26a, please explain:
27.Have you, or has any member of your family, ever had a dispute concerning money
❑ Yes (self) ❑ Yes (friend or family member) ‘No
27a.If yes, is there anything about that experience that would prevent you from acting as
❑ Yes o No

| ------ | ------------------------------------------------------------------------------------------------------------------------ | | 28. | Do you or any member of your family or a close friend work in law, law enforcement, the justice system, or the courts? | | | o Yes < No |

28b.If yes to 28, would this affect your ability to serve as a fair and impartial juror in
28c.If yes to 28b, please explain:
29.Do you know or have any association—professional, business, or social, direct or
❑ Yes kicNo
29a.If yes, please explain:
29b.If yes to 29, would this affect your ability to serve as a fair and impartial juror in
o Yes ❑ No
29c.If yes to 29b, please explain:
30.Do you know or have any association—professional, business, or social, direct or
❑ Yes istt No
30b.If yes to 30, would this affect your ability to serve as a fair and impartial juror in
30c.If yes to 30b, please explain:
31.Do you know or have any association—professional, business, or social, direct or
❑ Yes *No
31a.If yes, please explain:
31 b.If yes to 31, would this affect your ability to serve as a fair and impartial juror in
31c.If yes to 31b, please explain:
32.Do you have any opinion of the U.S. Attorne ‘s Office for the Southern District of
New York, the U.S. Attorney Damian or the former Acting U.S. Attorney
❑ Yes *No

| ----------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 33. | The next subset of questions asks whether you or any member of your family or a close friend personally knows or has past or present dealings with individuals involved in this case. To “personally know” means to have some direct or personal knowledge or connection to the following individuals. If you have only heard the names through media or social media, for example, that is not personal knowledge. | | 33a. | Do you or does any member of your family or a close friend personally know or have past or present dealings with the Defendant in this case, Ghislaine Maxwell, or her family members?

Yes No | | 33b. | Do you or does any member of your family or a close friend personally know or have past or present dealings with Jeffrey Epstein?

Yes No | | 33c. | Do you or does any member of your family or a close friend personally know or have past or present dealings with the U.S. Attorney for the Southern District of New York, Damian [REDACTED], the former Acting U.S. Attorney for the Southern District of New York, Audrey Strauss, or anyone else who works for or used to workrk for the U.S. Attorney’s Office for the Southern District of New York?

Yes No | | 33d. | Do you or does any member of your family or a close friend personally know or have past or present dealings with any of the Assistant United States Attorneys who are prosecuting this case:

Maurene Comey Yes No
Alison Moe Yes No
Lara Pomerantz Yes No
Andrew Rohrbach Yes No |

33e.Do you or does any member of your family or a close friend personallyknow or
Christian Everdell of& Gresser LLP o Yes No
Jeffrey Pagliuca of Haddon,and M, P.C. a Yes tk No
Laura Menninger of Haddon,and P.C. o Yes c(No
33f.Do you or does any member of your family or a close friend personallyknow or
o Yescg No
33g.If you answered “yes” to any of the above sub-questions (33a, 33b, 33c, 33d, 33e,

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

This case has been widely reported in the national and local media. There is nothing wrong with having heard something about this case. It is important to answer all of the following questions truthfully and fully.

| | 34. |

Before today, had you read, seen, or heard anything about Ms. Maxwell?

Yes      No      Unsure

| | 34a. |

If yes or unsure, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website, social media). If you heard about Ms. Maxwell from a media source, please identify the media source by name:

Trementor hearing she was arrested on the news.














| | 35. |

Have you personally formed an opinion about Ms. Maxwell’s guilt or innocence of the crimes charged as a result of anything you have heard, read or seen?

Yes      No      Unsure

Not applicable, I have not read/seen/heard about Ms. Maxwell

| | 35a. |

If yes or unsure, please summarize your opinion:












|

Juror ID: 1)1

36.

Based on anything that you have read, seen, or heard about Ms. Maxwell, including anything about criminal charges against Ms. Maxwell, have you formed any opinions about Ms. Maxwell that might make it difficult for you to be a fair and impartial juror in this case?

Yes No Unsure

Not applicable, I have not read/seen/heard about Ms. Maxwell

36a.

If yes or unsure, please explain why it might be difficult for you to be a fair and impartial juror in this case:

37.

Before today, had you read, seen, or heard anything about Jeffrey Epstein?

Yes No Unsure

37a.

If yes or unsure, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website, social media). If you heard about Mr. Epstein from a media source, please identify the media source by name:

That he was arrested and that committed suicide. On the netware

38.

Have you verbally stated or posted your opinion on social media or online about Ms. Maxwell or Mr. Epstein?

Yes No

Not applicable, I have not read/seen/heard about Mr. Epstein/Ms. Maxwell

38a.

If yes, when and where did you state or post your opinion?

Juror ID: SI

39.Based on anything that you have read, seen, or heard about Jeffrey Epstein, have
o Yes 3No ❑ Unsure
39a.If yes or unsure, please explain why it might be difficult for you to be a fair and
40.If you have heard about Jeffrey Epstein, do you think Ms. Maxwell’s alleged
❑ Yes VW° ❑ Unsure
41.Based on anything you have read, seen, or heard about Ms. Maxwell, including
f Yes o No o Unsure

Juror ID: Si

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: {sup}2 , 7

| ------ | ------------------------------------------------------------------------------------- | | 45. | Have you or a family member ever supported, lobbied, petitioned, protested, or | | | o Yes KNo | | 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 | | 45c. | If yes to 45b, please explain: | | 46. | The witnesses in this case may include law enforcement witnesses. Would you have | | | o Yes Qtit No |

47.Witnesses in this case may testify claiming sexual abuse or sexual assault. Would
❑ Yes pc No
47a.If yes, please explain:
48.Have you or a friend or family member ever been the victim of sexual harassment,
❑ Yes (self) o Yes (friend or family member) V 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
49.Have you or a friend or family member ever been accused of sexual harassment,
a Yes (self) o Yes (friend or family member) etK 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
49c.If yes to 49b, please explain:
50.Is there any other experience that you or anyone close to you has had that may
❑ Yes g No
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 31declare 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 44 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.

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 a reasonable doubt.

The charges in the Indictment stem from allegations that from at least 1994 through 2004, the Defendant conspired with and aided and abetted Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity, to transport minors to engage in criminal sexual activity, and to engage in sex trafficking of a minor.

The Indictment charges the Defendant in 6 counts: Count One of the Indictment charges the Defendant with conspiring with Jeffrey Epstein and others to entice minors to travel to engage in sexual activity for which a person can be charged with a criminal offense. Count Two charges the Defendant with enticing a minor to travel to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Three charges the Defendant with conspiring with Epstein and others to transport minors to engage in sexual activity for which a person can be charged with a criminal offense. Count Four charges the Defendant with transporting a minor to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Five charges the Defendant with participating in a sex trafficking conspiracy. Count Six charges the Defendant with sex trafficking of a minor, and aiding and abetting the same.

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

Juror ID: q (6

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 fmancial hardship to be excused from service.

PLEASE ANSWER THE FOLLOWING QUESTIONS:

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

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
o Yes dNo
5a.If yes, please explain why you would be unable to get to court by 9:30 a.m. or
6.Do you have any difficulty reading, speaking, or understanding English?
o Yes dNo
7.Do you have any medical, physical, or mental condition or illness that makes you
o Yes c/No
7a.If yes, please briefly describe the condition or illness. If you believe you could serve
8.Are you taking any medication which would prevent you from giving full attention
o Yes rf/No

Juror ID: I S

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
10Underthelaw,thefactsare forthejurytodetermineand thelaw isfor theJudge to
determineYouarerequiredto acceptthe lawas theJudgeexplainsit toyou even if
youdonot likethelawordisagreewithit,and youmustdeterminethefacts
accordingtothoseinstructionsDoyouacceptthisprinciple,and willyoube able to
followtheJudge’sinstructionsifselectedtoserveonthis jury?
/YesoNo
10a Ifno,pleaseexplain:
11Thelawprovidesthata defendantinacriminalcaseis presumedinnocentat all
stagesofthetrial andis notrequiredtoputon anydefenseat allTheGovernment
isrequiredtoprovethedefendantguiltybeyond areasonabledoubtoneach charge
Doyouaccepttheseprinciples,andwillyoubeableto applythemifselected to
serveonthisjury?
/YesoNo
11 aIf no,pleaseexplain:

Juror ID: Lfr{sup}e )

12The lawprovidesthatadefendantinacriminalcasehasanabsoluterightnotto
testify,andthata jurorcannothold itagainstthedefendantifshechoosesnotto
testifyDoyouacceptthisprinciple,andwillyoube abletoapplyit ifselectedto
serveon thisjury?
le’Yes❑No
12aIf no,pleaseexplain:
13A jurorisrequiredby lawtomakehis orherdecisionbasedsolelyontheevidence
or lackofevidencepresentedin Court,andnot onthebasisofconjecture,suspicion ,
bias,sympathy,orprejudiceDo youacceptthisprinciple,andwill youbeable to
applyit ifselectedto serveonthisjury?
/Yes❑No
I 3aIf no,pleaseexplain:
14Underthelaw,thequestionofpunishmentisfortheCourtalonetodecide,and thus
theissueofpunishmentmustnotenterintoyourdeliberationsastowhetherthe
defendantis guiltyor notguilty aschargedDoyouacceptthisprinciple,and will
yoube abletoapplyitif selectedtoserveonthisjury?
/Yes❑No
14aIf no,pleaseexplain:

Juror ID: 4s

15 Youmayheartestimonyin thiscase thatlawenforcementofficersrecoveredcertain
evidencefromsearchesTheCourt willinstructyouthatthosesearcheswere legal
andthattheevidenceobtainedfromthosesearchesisadmissibleinthis caseDo
youhaveanyfeelings orop inionsaboutsearchesconductedbylawenforcement
officers,orthe useofevidenceobtainedfromsearches,thatwouldaffectyour
abilityto befairandimpartialin thiscase?
o Yes/No
15a Ifyes,p leaseexplain:
16Youalsomay heartestimonyin thiscase FromexpertwitnessesHaveyouhad any
experienceswithexperts, or doyouhave anygeneral feelingsaboutthe useof
exper ts,thatwouldaffectyourabilityto be fairandimpartialinthiscase?
oYesu/No
16a Ifyes,p leaseexplain:
17 Asinstructedabove,from nowanduntil yourjuryserviceiscomplete,you are
instructedto avoidallmediacoverageand notto goon theInternetwithregar d to
thiscase foranypurposeThatis, youareforbiddenfromconsuminganynews
mediaorsocialmedia,or anydiscussionofthis case(orof anyoneparticipating in
the case)outsideof thecourtroomwhatsoeverYoualsomustnotdiscussthis case
withanyoneThisincludes yourfamily,friends,spouse,domesticpartner,
colleagues,andco -workersTheseinstructionsapply fromnowanduntilyou are
eitherdismissedfromjuryselectionor chosenas ajurorand thetrialiscomp lete
Whenwereturnfor thenextstep injury selection,theJudge willaskyouif you
havefollowedthisinstruction
Do youhave anyreservationsorconcernsaboutyourability orwillingnessto
followthisinstruction?
oYesw /1 s e I o

Juror ID: (Pe

17a.If yes, please explain:






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

| --------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 18. |

Have you ever served as a juror in a trial in any court?

Yes No | | 19. |

Have you ever at any time served as a member of a grand jury, whether in federal, state, county, or city court?

Yes No |

EXPERIENCE AS A WITNESS, DEFENDANT, OR CRIME VICTIM
20.

Have you, or has any relative or close friend, ever participated in a state or federal court case, whether criminal or civil, as a witness, plaintiff, or defendant?

Yes (self)                      Yes (friend or family member)                      No

20a.

If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case?

Yes                                  No

20b.

If yes to 20a, please explain:

21.

Have you or any relative or close friend ever been involved or appeared as a witness in any investigation by a federal or state grand jury or by a congressional or state legislative committee, licensing authority, or governmental agency, or been questioned in any matter by any federal, state, or local law enforcement agency?

Yes (self)                      Yes (friend or family member)                      No

Juror ID: %{sup}s

21a Ifyes,isthereanythingaboutthat experience that would prevent you from acting as
afairandimpartialjurorinthiscase?
oYesiNo
21b Ifyesto21a,pleaseexplain:
22Haveyou, orhas anyrelativeor close friend , ever been subpoenaed for any inquiry
orinvestigation?
Yes (self)oYes (friend or family member) `+ 1 O
Ifyes,is thereanythingaboutthat experience that would prevent you from acting as
afair andimpartialjuror inthis case?
oYes42 / No
22bIfyes to22a,pleaseexplain:
23Haveyou , orhas anyrelativeor close friend , ever been arrested or charged with a
oYes (self)oYes (friend or family member) t1 No
23aIfyes,is thereanythingaboutthat experience that would prevent you from acting as
afairandimpartialjurorinthis case?
oYeso No
23bIfyesto 23a,pleaseexplain:

Juror ID: Cte

24 Haveyou,orhas anyrelativeorclosefriend,everbeenthesubjectof any
investigationoraccusationbyany grandjury,stateorfederal,or anyother
o Yes(self)o Yes(friendorfamilymember)0 41 o
24a If yes,isthereanythingaboutthat experiencethatwouldpreventyou from acting as
a fairandimpartialjurorin thiscase?
oYesoNo
24b If yesto24a, pleaseexplain:
25 Haveyou,orany ofyourrelativesorclosefriends,everbeenavictim of a crime?
42/Yes(self)tllhes(friendorfamilymember)a No
25a Ifyes, isthereanythingaboutthatexperiencethatwouldpreventyou from acting as
a fairandimpartialjurorin thiscase?
oYesVI°
25b Ifyes to25a,p leaseexplain:
26 Haveyou,orhas anymemberof yourfamilyor anyofyourclosefriends —either as
individualsorin thecourseoftheirbusinessaffairs—everbeen apar ty to a legal
actionordisputewiththeUnitedStates,or withanyoftheofficers,departments,
agencies,oremployeesof theUnitedStates,includingtheUnitedStates Attorney’s
Office,theFBI, ortheNYPD?
oYes(self)oYes(friendorfamilymember)/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:
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:


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?
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
29c.If yes to 29b, please explain:



_____
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?
30a.If yes, please explain:



_____

Juror ID: tfig

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: qs

32a.If yes, please explain:






--------------------------------------------------------------------------
PERSONAL RELATIONSHIP WITH CASE PARTICIPANTS
33.The next subset of questions asks whether you or any member of your family or a close friend personally knows or has past or present dealings with individuals involved in this case. To “personally know” means to have some direct or personal knowledge or connection to the following individuals. If you have only heard the names through media or social media, for example, that is not personal knowledge.
33a.Do you or does any member of your family or a close friend personally know or have past or present dealings with the Defendant in this case, Ghislaine Maxwell, or her family members?

Yes No
33b.Do you or does any member of your family or a close friend personally know or have past or present dealings with Jeffrey Epstein?

Yes No
33c.Do you or does any member of your family or a close friend personally know or have past or present dealings with the U.S. Attorney for the Southern District of New York, Damian [REDACTED], the former Acting U.S. Attorney for the Southern District of New York, Audrey Strauss, or anyone else who works for or used to work for the U.S. Attorney’s Office for the Southern District of New York?

Yes No
33d.Do you or does any member of your family or a close friend personally know or have past or present dealings with any of the Assistant United States Attorneys who are prosecuting this case:

Maurene Comey Yes No
Alison Moe Yes No
Lara Pomerantz Yes No
Andrew Rohrbach Yes No
33eDoyouordoesanymemberofyourfamilyora closefriendpersonallyknowor
havepast orpresentdealingswithanyofthe defenseattorneysor lawfirmswhoare
representingtheDefendant:
ChristianEverdellof& GresserLLPoYestio
JeffreyPagliucaofHaddon,and, P.Co Yestelo
LauraMenningerof Haddon,and,P .Ca YesjJo
BobbiStemheimof LawOfficesof BobbiCSternheimo YesNo
331Doyouordoesanymemberofyourfamilyoraclosefriendpersonallyknowor
havepastor present dealingswiththe UnitedStatesDistrictCourtJudgewhois
presidingoverthiscase,AlisonJ Nathan,oranyonewho worksonherstaff?
o Yes/No
33gIfyouanswered”yes”toany oftheabovesub-questions(33a,33b,33c,33d,33e,
or33f),pleaseexplain whomyouknow,howyouknowtheindividual(s),and
whetheryourrelationshipwiththatpersonmightmakeit difficultfor youtobe a
fairandimpartialjurorinthiscase:

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

This case has been widely reported in the national and local media. There is nothing wrong with having heard something about this case. It is important to answer all of the following questions truthfully and fully.

| | 34. |

Before today, had you read, seen, or heard anything about Ms. Maxwell?

Yes      No      Unsure

| | 34a. |

If yes or unsure, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website, social media). If you heard about Ms. Maxwell from a media source, please identify the media source by name:

I remember that Ms. Maxwell was IDENTIFIED AS A FRIEND OF JEFFREY EPSTEIN AND THAT SHE WAS CHARGED WITH A CRIME INVOLVING HIM.

I HEARD THIS OR NEWS BROADCAST, AS WELL AS READING AN ARTICLE IN THE NEWS PAPER.

| | 35. |

Have you personally formed an opinion about Ms. Maxwell’s guilt or innocence of the crimes charged as a result of anything you have heard, read or seen?

Yes      No      Unsure

Not applicable, I have not read/seen/heard about Ms. Maxwell

| | 35a. |

If yes or unsure, please summarize your opinion:

_____

|

36.

Based on anything that you have read, seen, or heard about Ms. Maxwell, including anything about criminal charges against Ms. Maxwell, have you formed any opinions about Ms. Maxwell that might make it difficult for you to be a fair and impartial juror in this case?

Yes

No

Unsure

Not applicable, I have not read/seen/heard about Ms. Maxwell

36a.

If yes or unsure, please explain why it might be difficult for you to be a fair and impartial juror in this case:

_____
_____
_____
_____

37.

Before today, had you read, seen, or heard anything about Jeffrey Epstein?

Yes

No

Unsure

37a.

If yes or unsure, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website, social media). If you heard about Mr. Epstein from a media source, please identify the media source by name:

_____
I HEARD THAT MR EPSTEIN WAS
ALLESTED ON CHARGES OF SEXUAL
MISCONDUCT. I HEARD THIS ON NEWS
BROADCAST AS WELL AS READING ARTICLES IN THE
NEWSPAPER.

38.

Have you verbally stated or posted your opinion on social media or online about Ms. Maxwell or Mr. Epstein?

Yes No

Not applicable, I have not read/seen/heard about Mr. Epstein/Ms. Maxwell

38a.

If yes, when and where did you state or post your 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

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

|

44aIfyes, pleaseexplain:
45Haveyouor afamilymembereversupported,lobbied,petitioned,protested, or
workedinanyothermannerforor againstany laws,regulations,or organizations
relatingtosextrafficking,sexcrimesaga instminors,sex abuse,orsexual
o YesZia
45aIfyes, pleaseexplain whenandwhatyou oryourfamilymemberdid:
45bIfyouranswerto45 wasyes, doyoubelievethatthiswouldaffectyour ability to
servefairlyandimpartiallyas ajurorin thiscase?
❑ Yes❑ No
45cIfyesto45b,please explain:
46Thewitnessesinthis casemayincludelawenforcementwitnessesWould you have
anydifficultyassessingthecredibilityof alawenforcementofficerjust like you
wouldanyotherwitness?
❑ YesA°
46aIf yes,pleaseexplain:

Juror ID: +e

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:










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:








Juror ID: Liff3

| ------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 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):




|

Juror ID: 14/t S

DECLARATION

I, Juror Number I €’ 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 disciicsed my answers with others, or received assistance in completing the questionnaire.

Signed this 01t day of November, {sup}2021

60/Lot_ f3

Juror ID: q e

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.

Juror ID: q i’

., Juror ID: QV -1

Juror ID: i__

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 a reasonable doubt.

The charges in the Indictment stem from allegations that from at least 1994 through 2004, the Defendant conspired with and aided and abetted Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity, to transport minors to engage in criminal sexual activity, and to engage in sex trafficking of a minor.

The Indictment charges the Defendant in 6 counts: Count One of the Indictment charges the Defendant with conspiring with Jeffrey Epstein and others to entice minors to travel to engage in sexual activity for which a person can be charged with a criminal offense. Count Two charges the Defendant with enticing a minor to travel to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Three charges the Defendant with conspiring with Epstein and others to transport minors to engage in sexual activity for which a person can be charged with a criminal offense. Count Four charges the Defendant with transporting a minor to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Five charges the Defendant with participating in a sex trafficking conspiracy. Count Six charges the Defendant with sex trafficking of a minor, and aiding and abetting the same.

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

Juror ID: J-k q

SCHEDULE

Potential jurors will be called back for further questioning and jury selection from Tuesday, November 16, 2021, through Friday, November 19, 2021. Your availability during that week will be required.

The trial will commence on Monday, November 29, 2021. The trial is expected to last about six weeks. Generally, trial will be held five days per week, Monday through Friday, from 9:30 a.m. until 5:00 p.m. Trial will not be held on Friday, December 24, 2021 (Christmas Eve Day) and Friday, December 31, 2021 (New Year’s Eve).

If you are selected as a juror, you will be required to be present for the taking of testimony and evidence for as long as the trial lasts. There are no plans to sequester the jury, which means you will go home every day after court.

All jury service involves some degree of hardship. Our court and justice system depends on citizens doing their civic duty to serve as jurors, which involves temporarily putting aside their regular business for jury service. The Court views service on a jury to be one of the highest duties a citizen owes to the United States. Mere inconvenience or the usual financial hardship of jury service will not be sufficient to excuse a prospective juror. You must show extraordinary personal or financial hardship to be excused from service.

Juror ID: if

PLEASE ANSWER THE FOLLOWING QUESTIONS:

| ------ | ------------------------------------------------------------------------------------------------------------------------------- | | 1. | Do you have any unmovable commitments between November 16, 2021, and | | | ❑ Yes r/No | | 1 a. | If yes, please explain (without indicating the name of where you work or the names who you are): | | 2. | Do you have any unmovable commitments between November 29, 2021, and | | | ❑ Yes riNo | | 2a. | If yes, please explain (without indicating the name of where you work or the names who you are): | | 3. | Do you have any international travel plans between now and November 29, 2021? | | | ❑ Yes tir No | | 4. | Do any circumstances exist such that serving on the jury in this case would entail serious hardship or extreme inconvenience? | | | ❑ Yes ri 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
❑ Yes rgitgo
5a.If yes, please explain why you would be unable to get to court by 9:30 a.m. or
6.Do you have any difficulty reading, speaking, or understanding English?
❑ Yes jNo
7.Do you have any medical, physical, or mental condition or illness that makes you
❑ Yes sa/No
7a.If yes, please briefly describe the condition or illness. If you believe you could serve
8.Are you taking any medication which would prevent you from giving full attention
a Yes ciNo

Juror ID: 14 9

9.Do you have any religious, philosophical, or other beliefs that would make you
o Yes isi/No

| ------------------------------------------------------ | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 10. |

Under the law, the facts are for the jury to determine and the law is for the Judge to determine. You are required to accept the law as the Judge explains it to you even if you do not like the law or disagree with it, and you must determine the facts according to those instructions. Do you accept this principle, and will you be able to follow the Judge’s instructions if selected to serve on this jury?

Yes No

| | 10a. |

If no, please explain:

| | 11. |

The law provides that a defendant in a criminal case is presumed innocent at all stages of the trial and is not required to put on any defense at all. The Government is required to prove the defendant guilty beyond a reasonable doubt on each charge. Do you accept these principles, and will you be able to apply them if selected to serve on this jury?

Yes No

| | 11a. |

If no, please explain:

|

Juror ID: i_tc?

12.The law provides that a defendant in a criminal case has an absolute right not to
is/Yes o No
12a.If no, please explain:
13.A juror is required by law to make his or her decision based solely on the evidence
tiYes o No
I3a.If no, please explain:
14.Under the law, the question of punishment is for the Court alone to decide, and thus
Is/Yes o No

Juror ID: L.f9 _

15.You may hear testimony in this case that law enforcement officers recovered certain
o Yes si/ ./o
15a.If yes, please explain:
16.You also may hear testimony in this case from expert witnesses. Have you had any
o Yes iiiNo
17.As instructed above, from now and until your jury service is complete, you are
o Yes at/No

Juror ID: Lkq

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?
oYes(self)oYes(friendorfamilymember)ti(No
20aIfyes, isthereany thingaboutthat experiencethatwouldpreventyoufromacting as
afair andimpartialjuror inthiscase?
oYesoNo
20bIfyes to20a,pleaseexp lain:
21Haveyouor anyrelativeorclosefriendever beeninvolvedorappeared asa witness
inanyinvestigationby afederalorstategran djuryor byacongressionalor state
legislativecommittee,licensingauthority,orgovernmentalagency,orbeen
questionedinanymatter byanyfederal,state,or locallawenforcementagency ?
oYes(self)o Yes(friend orfamilymember)diNo
21a.If yes, is there anything about that experience that would prevent you from acting as
o Yes 12/ No
21b.If yes to 21a, please explain:
22.Have you, or has any relative or close friend, ever been subpoenaed for any inquiry
o Yes (self) o Yes (friend or family member) II No
22a.If yes, is there anything about that experience that would prevent you from acting as
22b.If yes to 22a, please explain:
23.Have you, or has any relative or close friend, ever been arrested or charged with a
o Yes (self) o Yes (friend or family member) W’No
23a.If yes, is there anything about that experience that would prevent you from acting as

Juror ID: in

24.Have you, or has any relative or close friend, ever been the subject of any
o Yes (self) o Yes (friend or family member) 9/No
24a.If yes, is there anything about that experience that would prevent you from acting as
o Yes 0 No
24b.If yes to 24a, please explain:
25.Have you, or any of your relatives or close friends, ever been a victim of a crime?
o Yes (self) o Yes (friend or family member) tsr/ No
25a.If yes, is there anything about that experience that would prevent you from acting as
26.Have you, or has any member of your family or any of your close friends—either as
o Yes (self) o Yes (friend or family member) 9 / No

Juror ID: Lig

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:




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: 46?

32a.If yes, please explain:






--------------------------------------------------------------------------
PERSONALRELATIONSHIPWITHCASEPARTICIPANTS
33Thenextsubsetofquestionsaskswhetheryouor anymember ofyourfamilyor a
closefriendpersonallyknowsorhas past orpresentdealingswithindividuals
involvedin thiscaseTo”personallyknow”meansto havesomedirectorpersona l
knowledgeorconnectionto thefollowingindividualsIfyou haveonlyheard the
namesthroughmediaorsocialmedia,forexample,that isnotpersonalknowledge
33aDoyouordoesanymemberofyourfamilyoraclosefriendpersonallyknowor
havepas torpresentdealingswiththeDefendantinthiscase,GhislaineMaxwell, or
herfamilymembers?
o YesWi\lo
33bDoyouordoesanymemberof yourfamilyoraclosefriendpersonallyknowor
havepas torpresentdealingswithJeffreyEpstein?
o Yes1:2 /No
33cDoyouordoesanymemberofyourfamilyoraclosefriendpersonallyknow or
havepas torpresent dealinswiththe U.SAttorneyfortheSouthernDistrictof
NewYork,DamiantheformerActingU.SAttorneyfor theSouthern
DistrictofNewYork,AudreyStrauss,oranyoneelse whoworksforor usedto
workfortheU .SAttorney’sOfficefortheSouthernDistrict ofNewYork?
oYesta /No
33dDoyouordoesanymemberofyourfamilyoraclosefriendpersonallyknow or
havepast orpresentdealingswithanyof theAssistantUnitedStatesAttorneyswho
areprosecutingthis case:
MaureneComeya Yessa /No
AlisonMoeo YessiNo
LaraPomerantzo YesciNo
AndrewRohrbacho Yescr iNo

Juror ID: gq _

33eDoyouordoesanymemberofyourfamilyoraclosefriendpersonallyknowor
havepas t orpresentdealingswithany ofthedefenseattorneysorlawfi rmswho are
representingtheDefendant:
ChristianEverdellof&GresserLLPa Yeso/No
JeffreyPagliucaofHaddon,and,P .CoYeso/No
LauraMenningerofHaddon,and, P .CoYes g/No
BobbiSternheimof LawOfficesofBobbiCSternheimaYespro
33EDoyou ordoesanymemberofyourfamilyor aclosefriendpersonallyknowor
havepas tor presentdealingswiththeUnitedStatesDistrictCourtJudgewho is
presidingoverthiscase,AlisonJNathan,oranyonewhoworkson herstaff?
oYes
33gIfyouanswered”yes”toanyofthe abovesub-questions(33a,33b, 33c,33d,33e,
or330,pleaseexplainwhomyouknow,howyouknow theindividual(s),and
whetheryourrelationshipwiththatpersonmightmakeitdifficultforyouto be a
fairandimpartialjuror inthiscase:

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

This case has been widely reported in the national and local media. There is nothing wrong with having heard something about this case. It is important to answer all of the following questions truthfully and fully.

| | 34. |

Before today, had you read, seen, or heard anything about Ms. Maxwell?

Yes          No          Unsure

| | 34a. |

If yes or unsure, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website, social media). If you heard about Ms. Maxwell from a media source, please identify the media source by name:

I heard it on the News TV















| | 35. |

Have you personally formed an opinion about Ms. Maxwell’s guilt or innocence of the crimes charged as a result of anything you have heard, read or seen?

Yes          No          Unsure

Not applicable, I have not read/seen/heard about Ms. Maxwell

| | 35a. |

If yes or unsure, please summarize your opinion:












|

36Basedonany thingthatyouhaveread,seen, orheardaboutMsMaxwell,including
anythingaboutcriminalchargesagainstMsMaxwell,haveyouformedany
opinionsaboutMsMaxwellthatmightmakeit difficultforyouto beafair and
impartialjuror inthiscase?
os4QooUnsure
ot applicable,Ihavenotread/seen/heardabout MsMaxwell
36aIf yesorunsure,p leaseexplainwhyitmightbe difficultforyouto beafair and
impartialjuror inthiscase:
37Beforetoday,had youread,seen,orheardanythingaboutJeffreyEpstein?
te ,YesoNooUnsure
37aIf yesorunsure,p leasestatewhatyourememberhearing,and howorfromwhom
youmayhaveheard (e.g ,afriend,thenewspaper,awebsite,socialmedia)If you
heardaboutMrEpsteinfromamediasource,p leaseidentifythemediasource by
S —kauteOn.irand’LADu fe, “Ile tug
38Haveyouverballystatedorpostedyouropinion onsocialmediaoronlineabout
MsMaxwellorrEpstein?
O YesNo
El Notapplicable,Ihavenotread/seen/heardabout MrEpstein/MsMaxwell
38aIfyes,when andwheredidyoustate orpos tyour opinion?

Juror ID: Li

39 Based onanythingthatyouhave read, seen , or heard about Jeffrey Epstein , have
you formedanyopinionsaboutMrEpstein that might make it difficult for you to
be a fair andimpartialjuror inthiscase?
❑Yes0 No0Unsure
❑Notapplicable,Ihavenot read/seen/heard about Mr Epstein
39a If yes orunsure,pleaseexplainwhyit might be difficult for you to be a fair and
impartialjuror inthiscase•
40 If you haveheardaboutJeffreyEpstein , do you think Ms Maxwell’s alleged
associationwithJeffreyEpsteinwillmake it difficult for you to fairly and
impartiallyconsidertheevidencepresented at trial and render a verdict based solely
on theevidence?
a Yes❑ No❑ Unsure
o Notapplicable,I havenot read/seen/heard about Ms Maxwell and/or
JeffreyEpstein
40a If yes orunsure,pleaseexplain:
41 Based onanythingyouhaveread ,seen , or heard about Ms Maxwell , including
anythingaboutcriminalchargesbrought against Ms Maxwell , would you be able to
follow theCourt’sinstructiontoput that information out of your mind and decide
this casebasedonly ontheevidencepresented at trial?
❑Yes❑NooUnsure
❑Notapplicable,Ihavenot read/seen/heard about Ms Maxwell

| ------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 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 impartialial 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: 1.1-61

44aIfyes, pleaseexplain:
45Haveyouor afamilymembereversupported,lobbied,petitioned,protested, or
workedinanyothermannerforor againstany laws,regulations,or organizations
relatingtosextrafficking,sexcrimesaga instminors,sex abuse,orsexual
o Yesto No
45aIfyes,p leaseexplain whenandwhatyou oryourfamilymemberdid:
45bIfyouranswerto45 wasyes, doyoubelievethatthiswouldaffectyour ability to
servefairlyandimpartiallyas ajurorin thiscase?
❑ Yes❑ No
45cIfyesto45b,please explain:
46Thewitnessesinthis casemayincludelawenforcementwitnessesWould you have
anydifficultyassessingthecredibilityof alawenforcementofficerjust like you
wouldanyotherwitness?
❑ Yes”2/No
46aIf yes,pleaseexplain:
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:

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:

Juror ID: to

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):




Juror ID: Li q

DECLARATION

I, Juror Number Li 9 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

1I R

Juror ID: Lig

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.

Juror ID: LI 9

Juror ID: Li (1

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 a reasonable doubt.

The charges in the Indictment stem from allegations that from at least 1994 through 2004, the Defendant conspired with and aided and abetted Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity, to transport minors to engage in criminal sexual activity, and to engage in sex trafficking of a minor.

The Indictment charges the Defendant in 6 counts: Count One of the Indictment charges the Defendant with conspiring with Jeffrey Epstein and others to entice minors to travel to engage in sexual activity for which a person can be charged with a criminal offense. Count Two charges the Defendant with enticing a minor to travel to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Three charges the Defendant with conspiring with Epstein and others to transport minors to engage in sexual activity for which a person can be charged with a criminal offense. Count Four charges the Defendant with transporting a minor to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Five charges the Defendant with participating in a sex trafficking conspiracy. Count Six charges the Defendant with sex trafficking of a minor, and aiding and abetting the same.

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

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 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 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—C)

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?
‘14Yes❑No
10a If no,pleaseexplain:
11 Thelawprovidesthatadefendantinacriminalcaseispresumedinnocentatall
stagesofthetrialandisnotrequiredtoput onanydefenseatallThe Government
is requiredtoprovethedefendantguiltybeyondareasonabledoubtoneachcharge
Doyouaccepttheseprinciples,andwillyoube abletoapplythemif selectedto
serveonthisjury?
XYes❑No
11 a Ifno, pleaseexplain:

Juror ID: 5 °

12Thelawprovidesthat a defendant in a criminal case has an absolute right not to
testify,andthatajuror cannot hold it aga inst the defendant if she chooses not to
testifyDoyouaccept this pr inciple, and will you be able to app ly it if selected to
serveonthisjury?
)(Yes ❑ No
12aIfno,p leaseexplain:
13Ajuroris requiredby law to make his or her decision based solely on the evidence
orlackof evidencepresen ted in Court, and not on the basis of conjecture, susp icion,
bias,sympathy,or prejudice Do you accep t this pr inciple, and will you be able to
applyitif selectedto serve on this jury?
S Yes ❑ No
13aIfno,pleaseexplain:
14Underthelaw,the ques tion of pun ishment is for the Court alone to decide, and thus
theissueofpunishment must not enter into your deliberations as to whether the
defendantis guilty or not gu ilty as charged Do you accep t this pr inciple, and will
youbeabletoapp ly it if selected to serve on this jury?
Yes ❑ No
14aIfno,p leaseexplain:
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?
❑ YesXNo
16a Ifyes,p leaseexplain:
17 Asinstructedabove,from nowanduntilyourjuryserviceis complete,you are
instructedtoavoidallmediacoverageandnotto goon theInternetwithregar d to
thiscase foranypurposeThatis, 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:






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

| --------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 18. |

Have you ever served as a juror in a trial in any court?

Yes No

| | 19. |

Have you ever at any time served as a member of a grand jury, whether in federal, state, county, or city court?

Yes No

|

EXPERIENCE AS A WITNESS, DEFENDANT, OR CRIME VICTIM
20.

Have you, or has any relative or close friend, ever participated in a state or federal court case, whether criminal or civil, as a witness, plaintiff, or defendant?

Yes (self)                      Yes (friend or family member)                      No

20a.

If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case?

Yes                      No

20b.

If yes to 20a, please explain:

21.

Have you or any relative or close friend ever been involved or appeared as a witness in any investigation by a federal or state grand jury or by a congressional or state legislative committee, licensing authority, or governmental agency, or been questioned in any matter by any federal, state, or local law enforcement agency?

Yes (self)                      Yes (friend or family member)                      No

21aIfyes,isthereanythingaboutthatexperiencethatwouldpreventyoufromactingas
afairandimpartialjurorinthiscase?
oYeso No
21bIfyesto21a,pleaseexp lain:
22Haveyou,orhasanyrelativeorclosefriend,everbeensubpoenaedforanyinquiry
orinvestigation?
❑Yes(self)❑Yes(friendorfamilymember))1 1 4 /No
22aIf yes,is thereanythingabout thatexperiencethat wouldprevent youfromacting as
afairandimpartialjuror inthiscase?
❑Yeso No
22bIfyes to22a,pleaseexp lain:
23Haveyou,orhas anyrelativeorclosefriend,everbeenarrestedorchargedwith a
❑Yes(self)o Yes(friendorfamilymember)No
23aIfyes,isthereanythingaboutthatexperiencethatwouldpreventyoufromacting as
afairandimpartialjurorin thiscase?
❑ Yes❑No
23bIfyesto23a, pleaseexplain:
24 Haveyou,or hasanyrelativeorclosefriend,everbeenthesubjectof any
investigationoraccusationbyany grand jury,state orfederal,or anyother
oYes(self)a Yes(friendorfamilymember))(No
24a If yes,isthereany thingaboutthat experiencethatwouldpreventyou from acting as
a fairandimpartialjurorin thiscase?
oYesoNo
24b If yesto24a, pleaseexplain:
25 Haveyou,orany ofyourrelativesorclosefriends,everbeenavictim of a crime?
o Yes(self)oYes(friendorfamilymember)XNo
25a If yes,isthereanythingaboutthatexperiencethatwouldpreventyou from acting as
a fairandimpartialjurorin thiscase?
oYesoNo
25b Ifyes to25a, pleaseexplain:
26 Haveyou,orhas anymemberof yourfamilyor anyofyourclosefriends —either as
individualsorin thecourseoftheirbusinessaffairs—everbeen aparty to a legal
actionordisputewiththeUnitedStates,or withanyoftheofficers,departments,
agencies,oremployeesof theUnitedStates,includingtheUnitedStates Attorney’s
Office,theFBI, ortheNYPD?
oYes(self)oYes(friendorfamilymember)X No

Juror ID: 5 -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:







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:

| |

-----------------------------------------------------------
PERSONALRELATIONSHIPWITHCASEPARTICIPANTS
33Thenextsubsetofquestions askswhetheryouoranymemberofyourfamilyor a
closefriendpersonallyknowsor haspas torpresentdealingswithindividuals
involvedin thiscaseTo”personallyknow”meansto havesomedirectorpersonal
knowledgeorconnectionto thefollowingindividualsIfyou haveonlyheardthe
namesthroughmediaorsocialmedia,forexample,that isnotpersonalknowledge
33aDoyouordoesanymemberofyourfamilyoraclosefriendpersonallyknowor
havepas torpresent dealingswiththeDefendantinthiscase,GhislaineMaxwell, or
herfamilymembers?
o YesXNo
33bDo youordoesanymemberofyourfamilyoraclosefriendpersonallyknowor
havepas torpresentdealingswithJeffreyEpstein?
o YesXNo
33cDoyouordoes anymemberof yourfamilyoraclosefriendpersonallyknow or
havepast orpresentwiththe U.SAttorneyfortheSouthernDistrictof
NewYork,Damian,theformerActingU.SAttorneyfor theSouthern
DistrictofNewYork,AudreyStrauss,oranyoneelse whoworksfororused to
workfortheU .SAttorney’sOfficefortheSouthernDistrict ofNewYork?
oYesI XNo
33dDoyouordoesanymemberofyourfamilyoraclosefriendpersonaltyknow or
havepast orpresentdealingswithanyof theAssistantUnitedStatesAttorneys who
areprosecutingthis case:
MaureneComeyo Yes)(No
AlisonMoeo YesXNo
LaraPomerantzo YesXNo
Andrew Rohrbacho Yes)(No

Juror ID: 6-0

33eDoyouordoesanymemberofyourfamilyor aclosefriendpersonallyknowor
havepas torpresentdealingswithany ofthedefenseattorneysorlawfirmswho are
representing theDefendant:
ChristianEverdellofBM&GresserLLP❑ YesgNo
JeffreyPagliucaofHaddon,andP .C❑ YesgNo
LauraMenningerofHaddon,andEMIP .C❑Yes)(No
BobbiStemheimof LawOfficesofBobbiCSternheim❑YesX No
331Doyou ordoesanymember ofyourfamilyor aclosefriendpersonallyknowor
havepas torpresentdealingswiththeUnitedStatesDistrictCourtJudgewho is
presidingoverthiscase,AlisonJNathan,oranyonewhoworkson herstaff?
❑ YesyNo
33gIfyouanswered”yes” toanyofthe abovesub-questions(33a,33b, 33c,33d,33e,
or33f),pleaseexplainwhomyouknow,howyouknow theindividual(s),and
whetheryourrelationshipwiththatpersonmightmakeitdifficultforyouto be a
fairandimpartialjurorin thiscase:

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

This case has been widely reported in the national and local media. There is nothing wrong with having heard something about this case. It is important to answer all of the following questions truthfully and fully.

| | 34. |

Before today, had you read, seen, or heard anything about Ms. Maxwell?

Yes      No      Unsure

| | 34a. |

If yes or unsure, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website, social media). If you heard about Ms. Maxwell from a media source, please identify the media source by name:

I read on a website that she was Jeffrey Epstein’s girlfriend - source was CNN.com












| | 35. |

Have you personally formed an opinion about Ms. Maxwell’s guilt or innocence of the crimes charged as a result of anything you have heard, read or seen?

Yes      No      Unsure
Not applicable, I have not read/seen/heard about Ms. Maxwell

| | 35a. |

If yes or unsure, please summarize your opinion:












|

36Basedonany thingthatyouhaveread,seen,orheardaboutMsMaxwell,including
anythingaboutcriminalchargesagainstMsMaxwell,haveyouformedany
opinionsabout MsMaxwellthatmightmake itdifficultforyou tobea fairand
impartialjuror inthiscase?
o YesYkNooUnsure
o Notapplicable,Ihavenotread/seen/heardabout MsMaxwell
36aIf yesorunsure,p leaseexplainwhyitmight bedifficultforyouto beafair and
impartialjuror inthiscase:
37Beforetoday,had youread,seen,orheardanythingaboutJeffreyEpstein?
XYesoNooUnsure
37aIfyes orunsure,p leasestatewhatyourememberhearing,and howorfromwhom
youmayhaveheard (e.g .,afriend,thenewspaper,awebsite,socialmedia)If you
heardaboutMrEpsteinfroma mediasource,p leaseidentifythemediasource by
CONI S50A,CCte,\ e_and&GOAVC .%5afecfrh
006‘ ,‘tAput1.LV-iMIN)(AAGkAttckAn8t(1Cill
38Haveyouverballystatedorpostedyouropinion onsocialmediaoronlineabout
MsMaxwellor MrEpstein?
OYes)1(No
ONot applicable,Ihavenotread/seen/heardabout MrEpstein/MsMaxwell
38aIfyes,whenand wheredidyoustateor pos tyour opinion?

Juror ID: SO

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




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: SO

| ------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 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:






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:





















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.).

No
49a.

If yes, without listing names, please explain:

Juror ID: 5_{sup}o

| ------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 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 5° 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, {sup}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.

Juror ID: 5°

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.

Juror ID: 1-ct)

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 atrial commencing on Monday, November 29, 2021. Although it is never possible to predict the length of atrial, currently this trial is expected to last approximately six weeks.

This is a criminal case. The Defendant, Ghislaine Maxwell, has been charged in an Indictment with various criminal offenses. The Indictment is not evidence. It simply contains the charges—referred to as “counts”—that the Government intends to prove to the jury at trial beyond a reasonable doubt.

The charges in the Indictment stem from allegations that from at least 1994 through 2004, the Defendant conspired with and aided and abetted Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity, to transport minors to engage in criminal sexual activity, and to engage in sex trafficking of 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 {sup}aperson can be charged with acriminal offense. Count Two charges the Defendant with enticing a minor 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 {sup}aperson can be charged with acriminal offense. Count Four charges the Defendant with transporting a minor to engage in sexual activity for which {sup}aperson can be charged with acriminal offense, and aiding and abetting the same. Count Five charges the Defendant with participating in {sup}asex trafficking conspiracy. Count Six charges the Defendant with sex trafficking of aminor, and aiding and abetting the same.

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

Juror ID: 14D

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 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 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 aprospective juror. You must show extraordinary personal or financial hardship to be excused from service.

Juror ID: “l’t

PLEASE ANSWER THE FOLLOWING QUESTIONS:

| ------ | ------------------------------------------------------------------------------------------------------------------------------- | | 1. | Do you have any unmovable commitments between November 16, 2021, and | | | o Yes (No | | 1 a. | If yes, please explain (without indicating the name of where you work or the names who you are): | | 2. | Do you have any unmovable commitments between November 29, 2021, and | | | 0 Yes Iti No | | 2a. | If yes, please explain (without indicating the name of where you work or the names who you are): | | 3. | Do you have any international travel plans between now and November 29, 2021? | | | o Yes !r No | | 4. | Do any circumstances exist such that serving on the jury in this case would entail serious hardship or extreme inconvenience? | | | o Yes 11/No | | 4a. | If yes, please briefly describe the serious hardship or extreme inconvenience: |

Juror ID: —14D

5.Do you have any personal commitments that would make it difficult for you to get
o Yes is /No
5a.If yes, please explain why you would be unable to get to court by 9:30 a.m. or
6.Do you have any difficulty reading, speaking, or understanding English?
o Yes VNo
7.Do you have any medical, physical, or mental condition or illness that makes you
o Yes i(No
7a.If yes, please briefly describe the condition or illness. If you believe you could serve
8.Are you taking any medication which would prevent you from giving full attention
o Yes i/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
10Underthelaw,the factsarefor thejurytodetermineand thelaw isfor theJudge to
determineYouarerequiredto acceptthelaw astheJudge explains ittoyou even if
youdonot likethelawordisagreewithit,and youmustdeterminethe facts
accordingtothoseinstructionsDoyouacceptthisprinciple,and willyoube able to
followtheJudge’sinstructionsifselectedtoserveonthis jury?
VYesa No
10a Ifno,pleaseexp lain:
11Thelawprovidesthatadefendantin acriminalcase ispresumedinnocentat all
stagesofthetrialandis notrequ iredtoputon anydefenseatall TheGovernment
isrequiredtoprovethedefendantguiltybeyond areasonabledoubt oneachcharge
Doyouaccepttheseprinciples,andwillyoubeable toapp lythem ifselectedto
serveonthisjury?
leYesoNo
I la Ifno,pleaseexp lain:

Juror ID: -1-th

12Thelawprovidesthat adefendantinacriminalcase hasanabsoluteright notto
testify,andthat ajurorcannotholdit againstthedefendantif shechoosesnotto
testifyDo youacceptthisprinciple,andwillyoubeable toapply it ifselectedto
serve onthisjury?
h(Yeso No
12aIfno, pleaseexp lain:
13Ajuroris requiredby lawtomakehisor herdecisionbasedsolelyontheevidence
orlackofevidencepresentedinCourt,andnot onthebasisofconjecture,suspicion,
bias,sympathy,orprejudiceDo youacceptthispr inciple,andwill youbeable to
apply itifselected toserveonthisjury?
1lYesoNo
13aIfno, pleaseexp lain:
14Underthelaw,thequestionofpunishmentisforthe Courtaloneto decide,and thus
theissueofpunishmentmust notenterintoyourdeliberationsastowhetherthe
defendantis guilty ornotgu iltyaschargedDo youacceptthis principle,andwill
youbeable toapp lyit ifselectedtoserveonthisjury?
Is /YesoNo
14aIf no,please explain:

Juror ID: -1-4)

15.You may hear testimony in this case that law enforcement officers recovered certain
o Yes te(No
15a.If yes, please explain:
16.You also may hear testimony in this case from expert witnesses. Have you had any
o Yes tiNo
17.As instructed above, from now and until your jury service is complete, you are
o Yes 410
17a.If yes, please explain:






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

| --------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 18. |

Have you ever served as a juror in a trial in any court?

Yes No | | 19. |

Have you ever at any time served as a member of a grand jury, whether in federal, state, county, or city court?

Yes No |

EXPERIENCE AS A WITNESS, DEFENDANT, OR CRIME VICTIM

EXPERIENCE AS A WITNESS, DEFENDANT, OR CRIME VICTIM
20.

Have you, or has any relative or close friend, ever participated in a state or federal court case, whether criminal or civil, as a witness, plaintiff, or defendant?

Yes (self)                      Yes (friend or family member)                      No

20a.

If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case?                      No

Yes                      No

20b.

If yes to 20a, please explain:

21.

Have you or any relative or close friend ever been involved or appeared as a witness in any investigation by a federal or state grand jury or by a congressional or state legislative committee, licensing authority, or governmental agency, or been questioned in any matter by any federal, state, or local law enforcement agency?

Yes (self)                      Yes (friend or family member)                      No

Juror ID: —4-C

21aIfyes,isthereanythingabout that experience that would prevent you from acting as
afairandimpartialjuror in this case? p i A
oYes o No
21bIfyes to21a,pleaseexplain:
22Haveyou,orhasanyrelative or close friend, ever been subpoenaed for any inquiry
orinvestigation?
oYes(self)o Yes (friend or family member) 8/No
22aIfyes,isthereanythingabout that experience that would prevent you from acting as
afairandimpartialjurorin this case? Nip
oYes o No
22bIfyesto22a,pleaseexplain:
23Haveyou,orhasanyrelative or close friend, ever been arrested or charged with a
oYes(self)o Yes (friend or family member) ‘No
23aIfyes,isthereanythingabout that experience that would prevent you from acting as
afairandimpartialjurorin this case? MA
0Yes o No
23bIfyesto23a,pleaseexplain:
24.

Have you, or has any relative or close friend, ever been the subject of any investigation or accusation by any grand jury, state or federal, or any other investigation?

Yes (self)                      Yes (friend or family member)                      No

24a.

If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case?                      Yes                      No

24b.

If yes to 24a, please explain:

25.

Have you, or any of your relatives or close friends, ever been a victim of a crime?

Yes (self)                      Yes (friend or family member)                      No

25a.

If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case?                      Yes                      No

25b.

If yes to 25a, please explain:

26.

Have you, or has any member of your family or any of your close friends—either as individuals or in the course of their business affairs—ever been a party to a legal action or dispute with the United States, or with any of the officers, departments, agencies, or employees of the United States, including the United States Attorney’s Office, the FBI, or the NYPD?

Yes (self)                      Yes (friend or family member)                      No

Juror ID: It

26aIfyes,isthereanythingaboutthatexperiencethatwouldpreventyoufromactingas
afairandimpartialjuror inthis case?( 1 4 / ., 1)1 fl
oYesci No
26bIfyesto26a,p leaseexp lain:
27Haveyou,orhas anymemberofyour family,everhada disputeconcerningmoney
owedtoyouby theGovernmentor owedby youto theGovernment?
oYes(self)oYes(friendor familymember)ii 7/%1 o
27aIfyes,isthereanythingaboutthatexperiencethatwouldpreventyoufromactingas
afairandimpartialjurorinthis case?N/il
oYesa No
27bIfyesto 27a,p leaseexp lain:
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:






28b.If yes to 28, would this affect your ability to serve as a fair and impartial juror in this case?
N/A
Yes No
28c.If yes to 28b, please explain:



29.Do you know or have any association—professional, business, or social, direct or indirect—with any member of the staff of the United States Attorney’s Office for the Southern District of New York?
Yes No
29a.If yes, please explain:



29b.If yes to 29, would this affect your ability to serve as a fair and impartial juror in this case?
N/A
Yes No
29c.If yes to 29b, please explain:



30.Do you know or have any association—professional, business, or social, direct or indirect—with the Federal Bureau of Investigation, commonly known as the FBI?
Yes No
30a.If yes, please explain:



30b.

If yes to 30, would this affect your ability to serve as a fair and impartial juror in this case?

N/A

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?

N/A

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: -a,

32a. If yes, please explain:

PERSONAL RELATIONSHIP WITH CASE PARTICIPANTS
33.The next subset of questions asks whether you or any member of your family or a close friend personally knows or has past or present dealings with individuals involved in this case. To “personally know” means to have some direct or personal knowledge or connection to the following individuals. If you have only heard the names through media or social media, for example, that is not personal knowledge.
33a.Do you or does any member of your family or a close friend personally know or have past or present dealings with the Defendant in this case, Ghislaine Maxwell, or her family members?

Yes No
33b.Do you or does any member of your family or a close friend personally know or have past or present dealings with Jeffrey Epstein?

Yes No
33c.Do you or does any member of your family or a close friend personally know or have past or present dealings with the U.S. Attorney for the Southern District of New York, Damian [REDACTED], the former Acting U.S. Attorney for the Southern District of New York, Audrey Strauss, or anyone else who works for or used to work for the U.S. Attorney’s Office for the Southern District of New York?

Yes No
33d.Do you or does any member of your family or a close friend personally know or have past or present dealings with any of the Assistant United States Attorneys who are prosecuting this case:

Maurene Comey Yes No
Alison Moe Yes No
Lara Pomerantz Yes No
Andrew Rohrbach Yes No

Juror ID: -TeP

33e.Do you or does any member of your family or a close friend personallyknow or
Christian Everdell of=& Gresser LLP o Yes 6/ No
Jeffrey Pagliuca of Haddonaanda, P.C. o Yes eiNo
Laura Menninger of Haddonma, P.C. o Yes vi No
33f.Do you or does any member of your family or a close friend personallyknow or
o YestrNo
33g.If you answered “yes” to any of the above sub-questions (33a, 33b, 33c, 33d, 33e,

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

This case has been widely reported in the national and local media. There is nothing wrong with having heard something about this case. It is important to answer all of the following questions truthfully and fully.

| | 34. |

Before today, had you read, seen, or heard anything about Ms. Maxwell?

Yes No Unsure

| | 34a. |

If yes or unsure, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website, social media). If you heard about Ms. Maxwell from a media source, please identify the media source by name:

Just news headlines around Epstein and her possibly being involved in his crimes, etc…

| | 35. |

Have you personally formed an opinion about Ms. Maxwell’s guilt or innocence of the crimes charged as a result of anything you have heard, read or seen?

Yes No Unsure

Not applicable, I have not read/seen/heard about Ms. Maxwell

| | 35a. |

If yes or unsure, please summarize your opinion:

|

36.

Based on anything that you have read, seen, or heard about Ms. Maxwell, including anything about criminal charges against Ms. Maxwell, have you formed any opinions about Ms. Maxwell that might make it difficult for you to be a fair and impartial juror in this case?

Yes      No      Unsure

Not applicable, I have not read/seen/heard about Ms. Maxwell

36a.

If yes or unsure, please explain why it might be difficult for you to be a fair and impartial juror in this case:

37.

Before today, had you read, seen, or heard anything about Jeffrey Epstein?

Yes      No      Unsure

37a.

If yes or unsure, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website, social media). If you heard about Mr. Epstein from a media source, please identify the media source by name:

_____
That he had a party ring with high profile people, who would engage in a veriety of illegal entertainment; usually outside the U.S.
I know he died in poison, but I don’t remember if he had already been sentenced or if he died while awaiting a trial.

38.

Have you verbally stated or posted your opinion on social media or online about Ms. Maxwell or Mr. Epstein?

Yes      No

Not applicable, I have not read/seen/heard about Mr. Epstein/Ms. Maxwell

38a.

If yes, when and where did you state or post your opinion?

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: 14)

41a.If no or unsure, please explain:

↗





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

| ------ | ----------------------------------------------------------------------------------------------------------------------------------------- | | 42. | During the trial, you will hear evidence alleging sex crimes against underage girls. you to be a fair and impartial juror in this case? | | | o Yes VNo | | 42a. | If yes, please explain: , | | 43. | Do you have any specific views or feelings concerning laws regarding the age at | | | o Yes I/ No | | 44. | Do you have any opinion about the enforcement of the federal sex trafficking laws from being fair and impartial in this case? | | | o Yes VNo |

Juror ID: -1 —Ctl

| ------ | ------------------------------------------------------------------------------------- | | 45. | Have you or a family member ever supported, lobbied, petitioned, protested, or | | | o Yes ti/ 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? NIA | | 45c. | If yes to 45b, please explain: | | 46. | The witnesses in this case may include law enforcement witnesses. Would you have | | | o Yes de’ o |

Juror ID: CD

47.Witnesses in this case may testify claiming sexual abuse or sexual assault. Would
❑ Yes 4Io
47a.If yes, please explain:
48.Have you or a friend or family member ever been the victim of sexual harassment,
❑ Yes (self) ❑ Yes (friend or family member) eislo
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? P-144

Juror ID: i -CD

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.).

No
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? N/A 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:-
-

| ------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 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 Number10 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 ti e’ day of November, 2021

76

Juror ID: —4

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.

Juror ID: 1 -0

Juror ID: 1 -12

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.

Juror ID: gct

Your name will not be disclosed or connected to this questionnaire beyond the Judge and the parties in this case. However, if you believe that any of your answers contain private information that could embarrass you or otherwise seriously compromise your privacy and wish to request that the Court keep them confidential and not distribute them beyond the Judge and parties, please indicate the particular question number at the end of the questionnaire.

SUMMARY OF THE CASE

The Court is selecting a jury for a trial commencing on Monday, November 29, 2021. Although it is never possible to predict the length of a trial, currently this trial is expected to last approximately six weeks.

This is a criminal case. The Defendant, Ghislaine Maxwell, has been charged in an Indictment with various criminal offenses. The Indictment is not evidence. It simply contains the charges—referred to as “counts”—that the Government intends to prove to the jury at trial beyond a reasonable doubt.

The charges in the Indictment stem from allegations that from at least 1994 through 2004, the Defendant conspired with and aided and abetted Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity, to transport minors to engage in criminal sexual activity, and to engage in sex trafficking of a minor.

The Indictment charges the Defendant in 6 counts: Count One of the Indictment charges the Defendant with conspiring with Jeffrey Epstein and others to entice minors to travel to engage in sexual activity for which a person can be charged with a criminal offense. Count Two charges the Defendant with enticing a minor to travel to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Three charges the Defendant with conspiring with Epstein and others to transport minors to engage in sexual activity for which a person can be charged with a criminal offense. Count Four charges the Defendant with transporting a minor to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Five charges the Defendant with participating in a sex trafficking conspiracy. Count Six charges the Defendant with sex trafficking of a minor, and aiding and abetting the same.

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

SCHEDULE

Potential jurors will be called back for further questioning and jury selection from Tuesday, November 16, 2021, through Friday, November 19, 2021. Your availability during that week will be required.

The trial will commence on Monday, November 29, 2021. The trial is expected to last about six weeks. Generally, trial will be held five days per week, Monday through Friday, from 9:30 a.m. until 5:00 p.m. Trial will not be held on Friday, December 24, 2021 (Christmas Eve Day) and Friday, December 31, 2021 (New Year’s Eve).

If you are selected as a juror, you will be required to be present for the taking of testimony and evidence for as long as the trial lasts. There are no plans to sequester the jury, which means you will go home every day after court.

All jury service involves some degree of hardship. Our court and justice system depends on citizens doing their civic duty to serve as jurors, which involves temporarily putting aside their regular business for jury service. The Court views service on a jury to be one of the highest duties a citizen owes to the United States. Mere inconvenience or the usual financial hardship of jury service will not be sufficient to excuse a prospective juror. You must show extraordinary personal or financial hardship to be excused from service.

PLEASE ANSWER THE FOLLOWING QUESTIONS:

| ----- | ------------------------------------------------------------------------------------------------------------------------------- | | 1. | Do you have any unmovable commitments between November 16, 2021, and | | | ❑ Yes fif No | | la. | If yes, please explain (without indicating the name of where you work or the names who you are): | | 2. | Do you have any unmovable commitments between November 29, 2021, and | | | ❑ Yes if No | | 2a. | If yes, please explain (without indicating the name of where you work or the names who you are): | | 3. | Do you have any international travel plans between now and November 29, 2021? | | | ❑ Yes pf No | | 4. | Do any circumstances exist such that serving on the jury in this case would entail serious hardship or extreme inconvenience? | | | ❑ Yes if 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
❑ Yes / No
5a.If yes, please explain why you would be unable to get to court by 9:30 a.m. or
6.Do you have any difficulty reading, speaking, or understanding English?
❑ Yes if No
7.Do you have any medical, physical, or mental condition or illness that makes you
❑ Yes fl No
7a.If yes, please briefly describe the condition or illness. If you believe you could serve
8.Are you taking any medication which would prevent you from giving full attention
o Yes ye No
9.Do you have any religious, philosophical, or other beliefs that would make you
❑ Yes ye No
10.Under the law, the facts are for the jury to determine and the law is for the Judge to
/Yes ❑ No
10a.If no, please explain:
11.The law provides that a defendant in a criminal case is presumed innocent at all serve on this jury?
‘Yes ❑ No
1 1 a.If no, please explain:
12.The law provides that a defendant in a criminal case has an absolute right not to
pi 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
yt Yes o No
13a.If no, please explain:
14.Under the law, the question of punishment is for the Court alone to decide, and thus
po’Yes ❑ No
15.You may hear testimony in this case that law enforcement officers recovered certain
❑ Yes ad No
15a.If yes, please explain:
16.You also may hear testimony in this case from expert witnesses. Have you had any
a Yes if No
17.As instructed above, from now and until your jury service is complete, you are
❑ Yes W No

| 17a. | If yes, please explain: |

| --------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 18. |

Have you ever served as a juror in a trial in any court?

Yes No

| | 19. |

Have you ever at any time served as a member of a grand jury, whether in federal, state, county, or city court?

Yes No

|

EXPERIENCE AS A WITNESS, DEFENDANT, OR CRIME VICTIM
20.

Have you, or has any relative or close friend, ever participated in a state or federal court case, whether criminal or civil, as a witness, plaintiff, or defendant?

Yes (self)                      Yes (friend or family member)                      No

20a.

If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case?

Yes                                  No

20b.

If yes to 20a, please explain:

21.

Have you or any relative or close friend ever been involved or appeared as a witness in any investigation by a federal or state grand jury or by a congressional or state legislative committee, licensing authority, or governmental agency, or been questioned in any matter by any federal, state, or local law enforcement agency?

Yes (self)                      Yes (friend or family member)                      No

Juror ID: i Ct

21a.If yes, is there anything about that experience that would prevent you from acting as
❑ Yes ‘No
21b.If yes to 21a, please explain:
22.Have you, or has any relative or close friend, ever been subpoenaed for any inquiry
❑ Yes (self) 0 Yes (friend or family member) o No
22a.If yes, is there anything about that experience that would prevent you from acting as
❑ Yes /No
22b.If yes to 22a, please explain:
23.Have you, or has any relative or close friend, ever been arrested or charged with a
❑ Yes (self) 0 Yes (friend or family member) ❑ No
23a.If yes, is there anything about that experience that would prevent you from acting as
❑ Yes yr No

Juror ID: / 4:1

24.Have you, or has any relative or close friend, ever been the subject of any
o Yes (self) ti Yes (friend or family member) o No
24a.If yes, is there anything about that experience that would prevent you from acting as
o Yes iteNo
24b.If yes to 24a, please explain:
25.Have you, or any of your relatives or close friends, ever been a victim of a crime?
af Yes (self) o Yes (friend or family member) o No
25a.If yes, is there anything about that experience that would prevent you from acting as
o Yes er No
26.Have you, or has any member of your family or any of your close friends—either as
o Yes (self) o Yes (friend or family member) pigo

Juror ID: .31

26a.If yes, is there anything about that experience that would prevent you from acting as
26b.If yes to 26a, please explain:
27.Have you, or has any member of your family, ever had a dispute concerning money
o Yes (self) o Yes (friend or family member) “0
27a.If yes, is there anything about that experience that would prevent you from acting as

| ------ | ------------------------------------------------------------------------------------------------------------------------ | | 28. | Do you or any member of your family or a close friend work in law, law enforcement, the justice system, or the courts? | | | o Yes ed No |

28b.If yes to 28, would this affect your ability to serve as a fair and impartial juror in
28c.If yes to 28b, please explain:
29.Do you know or have any association—professional, business, or social, direct or
0 Yes ii/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
29c.If yes to 29b, please explain:
30.Do you know or have any association—professional, business, or social, direct or
❑ Yes jr No

Juror ID: AI__

30b.If yes to 30, would this affect your ability to serve as a fair and impartial juror in
30c.If yes to 30b, please explain:
31.Do you know or have any association—professional, business, or social, direct or
o Yes dieNo
31a.If yes, please explain:
31b.If yes to 31, would this affect your ability to serve as a fair and impartial juror in
31c.If yes to Mb, please explain:
32.Do you have any opinion of the U.S. Attorne ‘s Office for the Southern District of
New York, the U.S. Attorney Damian or the former Acting U.S. Attorney
o Yes l iNo

Juror ID: gi

PERSONAL RELATIONSHIP WITH CASE PARTICIPANTS
33.The next subset of questions asks whether you or any member of your family or a close friend personally knows or has past or present dealings with individuals involved in this case. To “personally know” means to have some direct or personal knowledge or connection to the following individuals. If you have only heard the names through media or social media, for example, that is not personal knowledge.
33a.Do you or does any member of your family or a close friend personally know or have past or present dealings with the Defendant in this case, Ghislaine Maxwell, or her family members?

Yes No
33b.Do you or does any member of your family or a close friend personally know or have past or present dealings with Jeffrey Epstein?

Yes No
33c.Do you or does any member of your family or a close friend personally know or have past or present dealings with the U.S. Attorney for the Southern District of New York, Damian [REDACTED] the former Acting U.S. Attorney for the Southern District of New York, Audrey Strauss, or anyone else who works for or used to work for the U.S. Attorney’s Office for the Southern District of New York?

Yes No
33d.Do you or does any member of your family or a close friend personally know or have past or present dealings with any of the Assistant United States Attorneys who are prosecuting this case:

Maurene Comey Yes No
Alison Moe Yes No
Lara Pomerantz Yes No
Andrew Rohrbach Yes No
33e.Do you or does any member of your family or a close friend personallyknow or
Christian Everdell of an&Grosser LLP ❑ Yes a No
Jeffrey Pagliuca of Haddon,and P.C. ❑ Yes AP No
Laura Menninger of Haddon, andP.C. ❑ Yes No
Bobbi Stemheim of Law Offices of Bobbi C. Stemheim❑ Yes AIN°
33f.Do you or does any member of your family or a close friend personallyknow or
❑ Yesof No
33g.If you answered “yes” to any of the above sub-questions (33a, 33b, 33c, 33d, 33e,

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

This case has been widely reported in the national and local media. There is nothing wrong with having heard something about this case. It is important to answer all of the following questions truthfully and fully.

| | 34. |

Before today, had you read, seen, or heard anything about Ms. Maxwell?

Yes      No      Unsure

| | 34a. |

If yes or unsure, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website, social media). If you heard about Ms. Maxwell from a media source, please identify the media source by name:

I HAVE HEARD HER NAME BUT DO NOT KNOW ANY DETAILS OF THE CASE / CHARGES











| | 35. |

Have you personally formed an opinion about Ms. Maxwell’s guilt or innocence of the crimes charged as a result of anything you have heard, read or seen?

Yes      No      Unsure

Not applicable, I have not read/seen/heard about Ms. Maxwell

| | 35a. |

If yes or unsure, please summarize your opinion:











|

36.

Based on anything that you have read, seen, or heard about Ms. Maxwell, including anything about criminal charges against Ms. Maxwell, have you formed any opinions about Ms. Maxwell that might make it difficult for you to be a fair and impartial juror in this case?

Yes No Unsure

Not applicable, I have not read/seen/heard about Ms. Maxwell

36a.

If yes or unsure, please explain why it might be difficult for you to be a fair and impartial juror in this case:

37.

Before today, had you read, seen, or heard anything about Jeffrey Epstein?

Yes No Unsure

37a.

If yes or unsure, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website, social media). If you heard about Mr. Epstein from a media source, please identify the media source by name:


I HAVE HEARD HIS NAME IN THE NEWS
AND I AM AWARE OF HE COMMITTED
SUICIDE WHILE IN AIL.

38.

Have you verbally stated or posted your opinion on social media or online about Ms. Maxwell or Mr. Epstein?

Yes No

Not applicable, I have not read/seen/heard about Mr. Epstein/Ms. Maxwell

38a.

If yes, when and where did you state or post your opinion?

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:




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

| ------ | ----------------------------------------------------------------------------------------------------------------------------------------- | | 42. | During the trial, you will hear evidence alleging sex crimes against underage girls. you to be a fair and impartial juror in this case? | | | o Yes ,oll No | | 42a. | If yes, please explain: | | 43. | Do you have any specific views or feelings concerning laws regarding the age at | | | o Yes /No | | 44. | Do you have any opinion about the enforcement of the federal sex trafficking laws from being fair and impartial in this case? | | | o Yes pf No |

| ------ | ------------------------------------------------------------------------------------- | | 45. | Have you or a family member ever supported, lobbied, petitioned, protested, or | | | ❑ 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 | | 45c. | If yes to 45b, please explain: | | 46. | The witnesses in this case may include law enforcement witnesses. Would you have | | | ❑ Yes (No |

47.Witnesses in this case may testify claiming sexual abuse or sexual assault. Would
❑ Yes “No
47a.If yes, please explain:
48.Have you or a friend or family member ever been the victim of sexual harassment,
❑ 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
49.Have you or a friend or family member ever been accused of sexual harassment,
❑ Yes (self) o Yes (friend or family member) wNo
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
0 Yes o 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
o Yes / No
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

1, Juror Number VI 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 9 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.

Juror ID: Sl

Juror ID: (i)\

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 a reasonable doubt.

The charges in the Indictment stem from allegations that from at least 1994 through 2004, the Defendant conspired with and aided and abetted Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity, to transport minors to engage in criminal sexual activity, and to engage in sex trafficking of a minor.

The Indictment charges the Defendant in 6 counts: Count One of the Indictment charges the Defendant with conspiring with Jeffrey Epstein and others to entice minors to travel to engage in sexual activity for which a person can be charged with a criminal offense. Count Two charges the Defendant with enticing a minor to travel to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Three charges the Defendant with conspiring with Epstein and others to transport minors to engage in sexual activity for which a person can be charged with a criminal offense. Count Four charges the Defendant with transporting a minor to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Five charges the Defendant with participating in a sex trafficking conspiracy. Count Six charges the Defendant with sex trafficking of a minor, and aiding and abetting the same.

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

SCHEDULE

Potential jurors will be called back for further questioning and jury selection from Tuesday, November 16, 2021, through Friday, November 19, 2021. Your availability during that week will be required.

The trial will commence on Monday, November 29, 2021. The trial is expected to last about six weeks. Generally, trial will be held five days per week, Monday through Friday, from 9:30 a.m. until 5:00 p.m. Trial will not be held on Friday, December 24, 2021 (Christmas Eve Day) and Friday, December 31, 2021 (New Year’s Eve).

If you are selected as a juror, you will be required to be present for the taking of testimony and evidence for as long as the trial lasts. There are no plans to sequester the jury, which means you will go home every day after court.

All jury service involves some degree of hardship. Our court and justice system depends on citizens doing their civic duty to serve as jurors, which involves temporarily putting aside their regular business for jury service. The Court views service on a jury to be one of the highest duties a citizen owes to the United States. Mere inconvenience or the usual financial hardship of jury service will not be sufficient to excuse a prospective juror. You must show extraordinary personal or financial hardship to be excused from service.

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:

Juror ID: //?

5.Do you have any personal commitments that would make it difficult for you to get
o Yes N No
5a.If yes, please explain why you would be unable to get to court by 9:30 a.m. or
6.Do you have any difficulty reading, speakin , or understanding English?
7.Do you have any medical, physical, or mental condition or illness that makes you
7a.If yes, please briefly describe the condition or illness. If you believe you could serve
8.Are you taking any medication which would prevent you from giving full attention
9.Do you have any religious, philosophical, or other beliefs that would make you

| ------------------------------------------------------ | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 10. |

Under the law, the facts are for the jury to determine and the law is for the Judge to determine. You are required to accept the law as the Judge explains it to you even if you do not like the law or disagree with it, and you must determine the facts according to those instructions. Do you accept this principle, and will you be able to follow the Judge’s instructions if selected to serve on this jury?

Yes No

| | 10a. |

If no, please explain:

| | 11. |

The law provides that a defendant in a criminal case is presumed innocent at all stages of the trial and is not required to put on any defense at all. The Government is required to prove the defendant guilty beyond a reasonable doubt on each charge. Do you accept these principles, and will you be able to apply them if selected to serve on this jury?

Yes No

| | 11a. |

If no, please explain:

|

Juror ID: 149___

12.The law provides that a defendant in a criminal case has an absolute right not to
”—el Yes o No
12a.If no, please explain:
13.A juror is required by law to make his or her decision based solely on the evidence
13a.If no, please explain:
14.Under the law, the question of punishment is for the Court alone to decide, and thus

Juror ID: / /7

15.You may hear testimony in this case that law enforcement officers recovered certain
15a.If yes, please explain:
16.You also may hear testimony in this case from expert witnesses. Have you had any
I6a.If yes, please explain:
17.As instructed above, from now and until your jury service is complete, you are
o Yes -’“----th No
17a.If yes, please explain:






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

| ----- | ----------------------------------------------------------------------------------- | | 18. | Have you eve served as a juror in a trial in any court? | | 19. | Have you ever at any time served as a member of a grand jury, whether in federal, |

EXPERIENCE AS A WITNESS, DEFENDANT, OR CRIME VICTIM
20.

Have you, or has any relative or close friend, ever participated in a state or federal court case, whether criminal or civil, as a witness, plaintiff, or defendant?

Yes (self) Yes (friend or family member) No
20a.

If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case?

Yes No
20b.

If yes to 20a, please explain:

21.

Have you or any relative or close friend ever been involved or appeared as a witness in any investigation by a federal or state grand jury or by a congressional or state legislative committee, licensing authority, or governmental agency, or been questioned in any matter by any federal, state, or local law enforcement agency?

Yes (self) Yes (friend or family member) No

Juror ID: / / 2

2 I a.If yes, is there anything about that experience that would prevent you from acting as
21b.If yes to 21a, please explain:
22.Have you, or has any relative or close friend, ever been subpoenaed for any inquiry
o Yes (self) o Yes (friend or family member) N ii No
22a.If yes, is there anything about that experience that would prevent you from acting as

Juror ID: //2

24 Haveyou,orhas anyrelativeor closefriend,everbeenthesubjectof any
investigationoraccusationbyany grandjury,stateorfederal,or anyother
a Yes(self)oYes (friendorfamilymember)Ni No
24a If yes,isthereanythingaboutthat experiencethatwouldpreventyou from acting as
a fairandimpartialjurorin thiscase?
oYesaNo
24b Ifyes to24a, pleaseexplain:
25 Haveyou,orany ofyourrelativesorclosefriends,everbeena viim of a crime?
o Yes(self)aYes(friendorfamilymember)No
25a Ifyes, isthereanythingaboutthatexperiencethatwouldpreventyou from acting as
afair andimpartialjurorin thiscase?
oYesaNo
25b Ifyes to25a,p leaseexplain:
26 Haveyou,orhas anymemberof yourfamilyor anyofyourclosefriends —either as
individualsorin thecourseoftheirbusinessaffairs—everbeenapar ty to a legal
action ordisputewiththeUnitedStates,or withanyoftheofficers,departments,
agencies,oremployeesof theUnitedStates,includingtheUnitedStates Attorney’s
Office,the FBI,ortheNYPD?
oYes(self)aYes(friendorfamilymember)No

Juror ID: / {sup}iT

26a.If yes, is there anything about that experience that would prevent you from acting as
26b.If yes to 26a, please explain:
27.Have you, or has any member of your family, ever had a dispute concerning money
o Yes (self) o Yes (friend or family member) e No
27a.If yes, is there anything about that experience that would prevent you from acting as

| ------ | ------------------------------------------------------------------------------------------------------------------------ | | 28. | Do you or any member of your family or a close friend work in law, law enforcement, the justice system, or the courts? | | | a Yes —’ ’ ‘-d No |

28b.If yes to 28, would this affect your ability to serve as a fair and impartial juror in
28c.If yes to 28b, please explain:
29.Do you know or have any association—professional, business, or social, direct or
o Yes ----Thth 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
29c.If yes to 29b, please explain:
30.Do you know or have any association—prokssional, business, or social, direct or
30b.If yes to 30, would this affect your ability to serve as a fair and impartial juror in
30c.If yes to 30b, please explain:
31.Do you know or have any association—professional, business, or social, direct or
N’ ‘
o Yes Nri No
3 la.If yes, please explain:
3 1 b.If yes to 31, would this affect your ability to serve as a fair and impartial juror in
3 lc.If yes to 31b, please explain:
32.Do you have any opinion of the U.S. &wait’? Office for the Southern District of
New York, the U.S. Attorney Damian fl , or the former Acting U.S. Attorney

Juror ID: /1?

PERSONAL RELATIONSHIP WITH CASE PARTICIPANTS
33.The next subset of questions asks whether you or any member of your family or a close friend personally knows or has past or present dealings with individuals involved in this case. To “personally know” means to have some direct or personal knowledge or connection to the following individuals. If you have only heard the names through media or social media, for example, that is not personal knowledge.
33a.Do you or does any member of your family or a close friend personally know or have past or present dealings with the Defendant in this case, Ghislaine Maxwell, or her family members?
Yes No
33b.Do you or does any member of your family or a close friend personally know or have past or present dealings with Jeffrey Ep [REDACTED]?
Yes No
33c.Do you or does any member of your family or a close friend personally know or have past or present dealings with the U.S. Attorney for the Southern District of New York, Damian [REDACTED], the former Acting U.S. Attorney for the Southern District of New York, Audrey Strauss, or anyone else who works for or used to work for the U.S. Attorney’s Office for the Southern District of New York?
Yes No
33d.Do you or does any member of your family or a close friend personally know or have past or present dealings with any of the Assistant United States Attorneys who are prosecuting this case:
Maurene Comey Yes No
Alison Moe Yes No
Lara Pomerantz Yes No
Andrew Rohrbach Yes No
Maurene Comey Yes NoAlison Moe Yes NoLara Pomerantz Yes NoAndrew Rohrbach Yes No
Maurene Comey Yes No
Alison Moe Yes No
Lara Pomerantz Yes No
Andrew Rohrbach Yes No

Juror ID: //y

33e Doyouordoesanymemberofyourfamilyor aclosefriendnalknow or
have past orpresentdealingswithanyof thedefenseattorneysorlaw\ rms ei who are
representingtheDefendant:
ChristianEverdellof&GresserLLPo\No
JeffreyPagliucaofHaddon,and, P .CoYNo
LauraMenningerofHaddon,and, P.CaYee No
BobbiStemheimofLawOfficesofBobbiCStemheimo YesNo
33f. Doyouordoesanymemberofyourfamilyor aclosefriendpersonallyknow or
have past orpresentdealingswiththeUnitedStatesDistrictCourtJudgewho is
presidingoverthis case,AlisonJNathan,oranyonewhoworks onherstaff?
oYesNo
33g Ifyouanswered”yes “to anyoftheabovesub -questions(33a,33b,33c,33d, 33e,
or330,p leaseexplainwhomyouknow,howyouknowtheindividual(s),and
whetheryourrelationshipwiththatpersonmightmakeitdifficultforyou to be a
fair andimpartialjurorinthis case:

Juror ID: / /

KNOWLEDGEOF CASEANDPEOPLE
Thiscasehasbeenwidelyreportedin thenationalandlocalmediaThere is
nothingwrongwithhavingheardsomethingaboutthiscase Itisimportant to
answerallofthefollowingquestionstruthfullyandfully
34Beforetoday,hadyouread,seen,orheard anythingabout MsMaxwell?
NIYesoNooUnsure
34aIf yesorunsure,pleasestatewhatyourememberhearing,andhoworfromwhom
youmayhaveheard(e .g, afriend,thenewspaper,awebsite,socialmedia)If you
heardaboutMsMaxwellfromamediasource,p leaseidentifythemediasource by
NsIlt h ” (WM:1,9da”?g 75im , 4z E /.94 eA l
ect07Vnemis7r oirci rncrccOe,q41ea) ti t
/17 1,Efsie;n,
35Haveyoupersonallyformedan opinion aboutMsMaxwell’sguiltorinnocence of
thecrimeschargedas aresultofanythingyou haveheard,read orseen?
oYesNEINoo Unsure
oNotapplicable,Ihave notread/seen/heardaboutMsMaxwell
35aIfyes orunsure,pleasesummarizeyour opinion:
36.

Based on anything that you have read, seen, or heard about Ms. Maxwell, including anything about criminal charges against Ms. Maxwell, have you formed any opinions about Ms. Maxwell that might make it difficult for you to be a fair and impartial juror in this case?

Yes No Unsure

Not applicable, I have not read/seen/heard about Ms. Maxwell

36a.

If yes or unsure, please explain why it might be difficult for you to be a fair and impartial juror in this case:

37.

Before today, had you read, seen, or heard anything about Jeffrey Epstein?

Yes No Unsure

37a.

If yes or unsure, please state what you remember hearing, and how or from whom you may have heard (e.g., a friend, the newspaper, a website, social media). If you heard about Mr. Epstein from a media source, please identify the media source by name:

I believe I heard Mr. Epstein’s passing.

_____

38.

Have you verbally stated or posted your opinion on social media or online about Ms. Maxwell or Mr. Epstein?

Yes No

Not applicable, I have not read/seen/heard about Mr. Epstein/Ms. Maxwell

38a.

If yes, when and where did you state or post your opinion?

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

| ------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 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: ly

44a. If yes, please explain: harassment? 45c. If yes to 45b, please explain: would any other witness? 46a. If yes, please explain:

| ------ | ------------------------------------------------------------------------------------- | | 45. | Have you or a family member ever supported, lobbied, petitioned, protested, or | | 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 | | 45c. | If yes to 45b, please explain: | | 46. | The witnesses in this case may include law enforcement witnesses. Would you have | | | 0 Yes No |

Juror ID: 41 79._

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.[REDACTED]
48a.
48b.
48c.[REDACTED]
49Haveyouor a friendorfamilymembereverbeenaccusedofsexualharassment,
sexualabuse,orsexualassault?(Thisincludesbothformalaccusations in a court of
law orinformalaccusationsinasocialor worksettingofactualorattempted sexual
assaultorotherunwantedsexualadvance,includingby astranger,acqua intance,
supervisor,teacher,orfamilymember.)
oYes(self)oYes(friendorfamilymember)-tl No
49a Ifyes,withoutlistingnamesp leaseexplain:
49b Ifyouranswer to49 wasyes,doyoubelievethatthiswouldaffectyour ability to
servefairlyandimpartiallyasa jurorinthiscase?
o YesoNo
49c Ifyesto49b, p leaseexplain:
50Isthere anyotherexperiencethatyouoranyoneclosetoyouhashad that may
affectyourabilityto servefairlyandimps’allyasa jurorinthiscase?
o YesNo
50aIf yes,please explain:

Juror ID: L I 9

CLOSING QUESTION
51.[REDACTED]
_____
_____

Juror ID: II?

DECLARATION

1, Juror Number Li 9 declare under penalty of perjury that the foregoing answers set forth in this Jury Questionnaire are true and correct to the best of my knowledge and belief. I have not discussed my answers with others, or received assistance in completing the questionnaire.

Signed this 4.0 day of November, 2021

Juror ID: II7

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.

A single curved line on a lined page. The line starts at the bottom left and curves upwards and to the right, forming a convex curve. The page is filled with horizontal lines for writing.Juror ID: 1 ) (i

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 a reasonable doubt.

The charges in the Indictment stem from allegations that from at least 1994 through 2004, the Defendant conspired with and aided and abetted Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity, to transport minors to engage in criminal sexual activity, and to engage in sex trafficking of a minor.

The Indictment charges the Defendant in 6 counts: Count One of the Indictment charges the Defendant with conspiring with Jeffrey Epstein and others to entice minors to travel to engage in sexual activity for which a person can be charged with a criminal offense. Count Two charges the Defendant with enticing a minor to travel to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Three charges the Defendant with conspiring with Epstein and others to transport minors to engage in sexual activity for which a person can be charged with a criminal offense. Count Four charges the Defendant with transporting a minor to engage in sexual activity for which a person can be charged with a criminal offense, and aiding and abetting the same. Count Five charges the Defendant with participating in a sex trafficking conspiracy. Count Six charges the Defendant with sex trafficking of a minor, and aiding and abetting the same.

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

SCHEDULE

Potential jurors will be called back for further questioning and jury selection from Tuesday, November 16, 2021, through Friday, November 19, 2021. Your availability during that week will be required.

The trial will commence on Monday, November 29, 2021. The trial is expected to last about six weeks. Generally, trial will be held five days per week, Monday through Friday, from 9:30 a.m. until 5:00 p.m. Trial will not be held on Friday, December 24, 2021 (Christmas Eve Day) and Friday, December 31, 2021 (New Year’s Eve).

If you are selected as a juror, you will be required to be present for the taking of testimony and evidence for as long as the trial lasts. There are no plans to sequester the jury, which means you will go home every day after court.

All jury service involves some degree of hardship. Our court and justice system depends on citizens doing their civic duty to serve as jurors, which involves temporarily putting aside their regular business for jury service. The Court views service on a jury to be one of the highest duties a citizen owes to the United States. Mere inconvenience or the usual financial hardship of jury service will not be sufficient to excuse a prospective juror. You must show extraordinary personal or financial hardship to be excused from service.

PLEASE ANSWER THE FOLLOWING QUESTIONS:

| ----- | ------------------------------------------------------------------------------------------------------------------------------- | | 1. | Do you have any unmovable commitments between November 16, 2021, and | | | o Yes ‘90 No | | la. | If yes, please explain (without indicating the name of where you work or the names who you are): | | 2. | Do you have any unmovable commitments between November 29, 2021, and | | | o Yes o | | 2a. | If yes, please explain (without indicating the name of where you work or the names who you are): | | 3. | Do you have any international travel plans between now and November 29, 2021? | | | a Yes 190No | | 4. | Do any circumstances exist such that serving on the jury in this case would entail serious hardship or extreme inconvenience? | | | o Yes IN° | | 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
a Yes ‘No
5a.If yes, please explain why you would be unable to get to court by 9:30 a.m. or
6.Do you have any difficulty reading, speaking, or understanding English?
a Yes 1PNo
7.Do you have any medical, physical, or mental condition or illness that makes you
o Yes -I No
7a.If yes, please briefly describe the condition or illness. If you believe you could serve
8.Are you taking any medication which would prevent you from giving full attention
o Yes ?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:



















10.Under the law, the facts are for the jury to determine and the law is for the Judge to
itg Yes a No
10a.If no, please explain:
11.The law provides that a defendant in a criminal case is presumed innocent at all serve on this jury? t
Yes a No
lla.If no, please explain:
12Thelawprovidesthat a defendant in a criminal case has an absolute right not to
testify,andthata juror cannot hold it aga inst the defendant if she chooses not to
testifyDoyouaccep t this pr inciple, and will you be able to app ly it if selected to
serveonthisjury?
1 9 Yes o No
12aIfno,pleaseexplain:
13Ajuroris requiredby law to make his or her decision based solely on the evidence
orlackof evidencepresen ted in Court, and not on the basis of conjecture, susp icion,
bias,sympathy,or prejudice Do you accep t this pr inciple, and will you be able to
applyitifselectedto serve on this jury?
itIOYes o No
13aIfno,pleaseexplain:
14Underthelaw,the ques tion of pun ishment is for the Court alone to decide, and thus
theissueofpunishment must not enter into your deliberations as to whether the
defendantis guilty or not gu ilty as charged Do you accep t this pr inciple, and will
youbeabletoapp ly it if selected to serve on this jury?
ap Yes o No
14aIfno,pleaseexplain:

Juror ID: :71-+

15.You may hear testimony in this case that law enforcement officers recovered certain
o Yes Wail)
15a.If yes, please explain:
16.You also may hear testimony in this case from expert witnesses. Have you had any
o Yes 1}/No
17.As instructed above, from now and until your jury service is complete, you are
o Yes ro

.Juror 11): jid-9-

17a.If yes, please explain:




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

| ------------------------------------------------------------------------------------------------- | --------------------- | | 18. Have you ever served as a juror in a trial in any court? | | | a Yes | &No | | 19. Have you ever at any time served as a member of a grand jury, state, county, or city court? | whether in federal, | | a Yes | y9 No |

EXPERIENCE AS A WITNESS, DEFENDANT, OR CRIME VICTIM
20.

Have you, or has any relative or close friend, ever participated in a state or federal court case, whether criminal or civil, as a witness, plaintiff, or defendant?

Yes (self)                      Yes (friend or family member)                      No

20a.

If yes, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case?

Yes                                  No

20b.

If yes to 20a, please explain:

21.

Have you or any relative or close friend ever been involved or appeared as a witness in any investigation by a federal or state grand jury or by a congressional or state legislative committee, licensing authority, or governmental agency, or been questioned in any matter by any federal, state, or local law enforcement agency?

Yes (self)                      Yes (friend or family member)                      No

Juror ID: 1n

21a.If yes, is there anything about that experience that would prevent you from acting as
21b.If yes to 21a, please explain:
22.Have you, or has any relative or close friend, ever been subpoenaed for any inquiry
o Yes (self) o Yes (friend or family member) /No
22a.If yes, is there anything about that experience that would prevent you from acting as
22b.If yes to 22a, please explain:
23.Have you, or has any relative or close friend, ever been arrested or charged with a
o Yes (self) “Yes (friend or family member) o No
23a.If yes, is there anything about that experience that would prevent you from acting as
o Yes yolslo

Juror ID: 1A-

24.Have you, or has any relative or close friend, ever been the subject of any

This document was truncated for web display. See the linked source PDF for the complete record.

New York Times letter to Judge Alison Nathan seeking unsealing of juror questionnaires

Court filings

An attorney of the New York Times asks Judge Alison Nathan to unseal Ghislaine Maxwell's new-trial motion and seated jurors' questionnaires.

Court Records: United States v. Maxwell (S.D.N.Y. 1:20-cr-00330) · Jan. 24, 2022

Document EFTA 02838592 The NewYork Times Company David McCraw Senior Vicc President & Deputy General Counsel T 212 556 4031 mccrawtinytimcs.com 6208th Avenue New York, NY 10018 nytimes.com January 24, 2022 VIA EMAIL AND FEDEX The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 The motion to unseal the questionnaires of the twelve seated jurors is GRANTED. The motion to unseal the Defendant's motion for a new trial is moot as the Defendant's motion for a new trial is docketed at Dkt. No. 613. SO OR…