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.¶
- 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):¶
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- Do you have any unmovable commitments between November 29, 2021, and approximately January 15, 2022, which is the estimated length for trial? 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):¶
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-
Do you have any international travel plans between now and November 29, 2021? o Yes rii/No
-
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.:
|
| 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:
|
| 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 personally | know or |
|---|---|
| Christian Everdell of UM& Gresser LLP | o Yes cs/go |
| Jeffrey Pagliuca of Haddon, and | P.C. o Yes frit |
| Laura Menninger of Haddon, and | P.C. o Yes 12410 |
| Bobbi Sternheim of Law Offices of Bobbi C. Stemheim o Yes | wfsio |
| 33f. Do you or does any member of your family or a close friend personally | know or |
| o Yes | do |
| 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
|¶| EXPERIENCE | AS | A WITNESS, | DEFENDANT, | OR | CRIME | VICTIM | |||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 20 | Have | you, | or | has | any relative | or | close | friend, | ever | par | ticipated | in | a | state | or federal | ||
| court | case, | whether | criminal | or civil, | as | a witness, | p laintiff, | or defendant? | |||||||||
| o Yes | (self) | o | Yes | (friend | or | family | member) | •jitNo | |||||||||
| 20a | If yes, | is | there | any | thing | about | that | exper | ience | that | would | preven | t you | from | acting as | ||
| a fair | and | impartial | juror | in this | case? | ||||||||||||
| ❑ Yes | o No | ||||||||||||||||
| 20b | If yes | to | 20a, | p lease | exp | lain: | |||||||||||
| 21 | Have | you | or | any | relative | or | close | friend | ever | been | involved | or appeare | d | as | a witness | ||
| in any | investigation | by | a federal | or state | gran | d jury | or | by a | congress | ional | or | state | |||||
| legislative | committee, | licensing | authority, | or | governmen | tal | agency, | or | been | ||||||||
| ques | tioned | in | any | matter | by | any | federal, | state, | or | local | law | enforcement | agency | ? | |||
| o Yes | (self) | o | Yes | (friend | or | family | member) | )(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 personally | know or |
|---|---|---|
| Christian Everdell of etc | Greaser LLP o Yes No | |
| Jeffrey Pagliuca of Haddon, and | lEM P.C. o Yes No | |
| Laura Menninger of Haddon, and | 1.= P.C. o Yes )( No | |
| 33f. | Do you or does any member of your family or a close friend personally | know or |
| o Yes | X. 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 | 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 personally | know or |
|---|---|
| Christian Everdell of MI& Gresser LLP | o Yes if No |
| Jeffrey Pagliuca of Haddon, and | P.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 personally | know or |
| o Yes | o 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 personally | know 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 personally | know 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 personally | know 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 personally | know or |
| o Yes | cg 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: |
| BASIC | LEGAL | PRINCIPLES | AND | MEDIA | RESTRICTIONS | ||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 10 | Under | the | law, | the | facts | are for | the | jury | to | determine | and the | law is | for the | Judge to | |
| determine | You | are | 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 | o | 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 | gu | ilty | 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 | o | No | |||||||||||||
| 11 a | If no, | please | explain: |
Juror ID: Lfr{sup}e )¶
| 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? | ||||||||||||||
| le’ | 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 | ||||||||||||||
| I 3a | 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 gu | ilty | or not | gu | ilty 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: |
Juror ID: 4s¶
| 15 You | may | hear | testimony | in this | case that | law | enforcement | officers | recovered | certain | |||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| evidence | from | searches | The | Court will | instruct | you | that | those | searches | were legal | |||
| and | that | the | evidence | obtained | from | those | searches | is | admissible | in | this case | Do | |
| you | have | any | feelings or | op inions | about | searches | conducted | by | law | enforcement | |||
| officers, | or | the use | of | evidence | obtained | from | searches, | that | would | affect | your | ||
| ability | to be | fair | and | impartial | in this | case? | |||||||
| o Yes | /No | ||||||||||||
| 15a If | yes, | p lease | exp | lain: | |||||||||
| 16 | You | also | may hear | testimony | in this | case From | exper | t | witnesses | Have | you | had any | |
| exper | iences | with | exper | ts, or do | you | have any | genera | l feelings | about | the use | of | ||
| exper ts, | that | would | affect | your | ability | to be fair | and | impartial | in | this | case? | ||
| o | Yes | u/No | |||||||||||
| 16a If | yes, | p lease | exp | lain: | |||||||||
| 17 As | instructed | above, | from now | and | until your | jury | service | is | comp | lete, | you are | ||
| instructed | to avoid | all | media | coverage | and not | to go | on the | Internet | with | regar d to | |||
| this | case for | any | purpose | That | is, you | are | forbidden | from | consuming | any | news | ||
| media | or | social | media, | or any | discussion | of | this case | (or | of anyone | par | ticipating in | ||
| the case) | outside | of the | courtroom | whatsoever | You | also | must | not | discuss | this case | |||
| with | anyone | This | includes your | family, | friends, | spouse, | domestic | par | tner, | ||||
| colleagues, | and | co -workers | These | instructions | app | ly from | now | and | until | you are | |||
| either | dismissed | from | jury | selection | or chosen | as a | juror | and the | trial | is | comp lete | ||
| When | we | return | for the | next | step in | jury selection, | the | Judge will | ask | you | if you | ||
| have | followed | this | instruction | ||||||||||
| Do you | have any | reservations | or | concerns | about | your | ability or | willingness | to | ||||
| follow | this | instruction? | |||||||||||
| o | Yes | w / | 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 If | yes, | is | there | anything | about | that experience that would prevent you from acting as | |
|---|---|---|---|---|---|---|---|
| a | fair | and | impartial | juror | in | this | case? |
| o | Yes | iNo | |||||
| 21b If | yes | to | 21a, | please | explain: | ||
| 22 | Have | you | , or | has any | relative | or close friend , ever been subpoenaed for any inquiry | |
| or | investigation? | ||||||
| Yes (self) | o | Yes (friend or family member) `+ 1 O | |||||
| If | yes, | is there | anything | about | that experience that would prevent you from acting as | ||
| a | fair and | impartial | juror in | this case? | |||
| o | Yes | 42 / 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 | ||
| o | Yes (self) | o | Yes (friend or family member) t1 No | ||||
| 23a | If | yes, | is there | anything | about | that experience that would prevent you from acting as | |
| a | fair | and | impartial | juror | in | this case? | |
| o | Yes | o No | |||||
| 23b | If | yes | to 23a, | please | explain: |
Juror ID: Cte¶
| 24 Have | you, | or | has any | relative | or | close | friend, | ever | been | the | subject | of any | |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| investigation | or | accusation | by | any gran | d | jury, | state | or | federal, | or any | other | ||
| o Yes | (self) | o Yes | (friend | or | family | member) | 0 41 o | ||||||
| 24a If yes, | is | there | any | thing | about | that exper | ience | that | would | preven | t | you from acting as | |
| a fair | and | impartial | juror | in this | case? | ||||||||
| o | Yes | o | No | ||||||||||
| 24b If yes | to | 24a, p | lease | exp | lain: | ||||||||
| 25 Have | you, | or | any of | your | relatives | or | close | friends, | ever | been | a | victim of a crime? | |
| 42/Yes | (self) | tllhes | (friend | or | family | member) | a No | ||||||
| 25a If | yes, is | there | any | thing | about | that | exper | ience | that | would | preven | t | you from acting as |
| a fair | and | impartial | juror | in this | case? | ||||||||
| o | Yes | VI° | |||||||||||
| 25b If | yes to | 25a, | p lease | exp | lain: | ||||||||
| 26 Have | you, | or | has any | member | of your | family | or any | of | your | close | friends —either as | ||
| individuals | or | in the | course | of | their | business | affairs | —ever | been a | par ty to a legal | |||
| action | or | dispute | with | the | United | States, | or with | any | of | the | officers, | departments, | |
| agenc | ies, | or | emp | loyees | of the | United | States, | including | the | United | States Attorney’s | ||
| Office, | the | FBI, or | the | NYPD? | |||||||||
| o | Yes | (self) | o | Yes | (friend | or | family | member) | /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 |
| 33e | Do | you | or | does | any | member | of | your | family | or | a close | friend | persona | lly | know | or | |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| have | pas | t or | presen | t | dealings | with | any | of | the defense | attorneys | or law | firms | who | are | |||
| represen | ting | the | Defendant: | ||||||||||||||
| Christian | Everdell | of | & Gresser | LLP | o | Yes | tio | ||||||||||
| Jeffrey | Pagliuca | of | Haddon, | and | , P | .C | o Yes | tel | o | ||||||||
| Laura | Menninger | of Haddon, | and | , | P .C | a Yes | jJo | ||||||||||
| Bobbi | Stemheim | of Law | Offices | of Bobbi | C | Sternheim | o Yes | No | |||||||||
| 331 | Do | you | or | does | any | member | of | your | family | or | a | close | friend | persona | lly | know | or |
| have | pas | t | or presen | t dealings | with | the United | States | District | Court | Judge | who | is | |||||
| pres | iding | over | this | case, | Alison | J Nathan, | or | anyone | who works | on | her | staff? | |||||
| o Yes | /No | ||||||||||||||||
| 33g | If | you | answered | ”yes” | to | any of | the | above | sub | -ques | tions | (33a, | 33b, | 33c, | 33d, | 33e, | |
| or | 33f), | p | lease | exp | lain whom | you | know, | how | you | know | the | individual(s), | and | ||||
| whether | your | relationship | with | that | person | might | make | it difficult | for you | to | be a | ||||||
| fair | and | impartial | juror | in | this | case: |
| ------------------------------ | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | |
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: _____ |
| 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
|¶| 44a | If | yes, p | lease | exp | lain: | ||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 45 | Have | you | or a | family | member | ever | supporte | d, | lobbied, | pe | titioned, | pro | tested, or | ||
| worked | in | any | other | manner | for | or aga | inst | any laws, | regu | lations, | or organ | izations | |||
| relating | to | sex | trafficking, | sex | crimes | aga inst | minors, | sex abuse, | or | sexual | |||||
| o Yes | Zia | ||||||||||||||
| 45a | If | yes, p | lease | exp | lain 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, | p | lease exp | lain: | ||||||||
| 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 | A | ° | |||||||||||||
| 46a | If yes, | p | lease | exp | lain: |
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 |
| EXPERIENCE | AS | A | WITNESS | , | DEFENDANT, | OR | CRIME | VICTIM | |||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 20 | Have | you, | or | has | any | relative | or | close | friend, | ever | par | ticipated | in | a | state | or | federal |
| court | case, | whether | criminal | or | civil, | as a | witness, | p | laintiff, | or | defendant? | ||||||
| o | Yes | (self) | o | Yes | (friend | or | family | member) | ti(No | ||||||||
| 20a | If | yes, is | there | any thing | about | that exper | ience | that | would | preven | t | you | from | acting as | |||
| a | fair and | impartial | juror in | this | case? | ||||||||||||
| o | Yes | o | No | ||||||||||||||
| 20b | If | yes to | 20a, | p | lease | exp lain: | |||||||||||
| 21 | Have | you | or any | relative | or | close | friend | ever been | involved | or | appeare | d as | a witness | ||||
| in | any | investigation | by a | federal | or | state | gran d | jury | or by | a | congress | ional | or state | ||||
| legislative | committee, | licensing | authority, | or | governmen | tal | agency, | or | been | ||||||||
| ques | tioned | in | any | matter by | any | federal, | state, | or local | law | enforcement | agency ? | ||||||
| o | Yes | (self) | o Yes | (friend or | family | member) | di | No |
| 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: | |
|---|---|---|
| ------ | ------------------------- | ------------------------------------------- |
| PERSONAL | RELATIONSHIP | WITH | CASE | PARTICIPANTS | |||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 33 | The | next | subset | of | ques | tions | asks | whether | you | or any | member of | your | family | or a | |||
| close | friend | persona | lly | knows | or | has pas | t or | presen | t | dealings | with | individuals | |||||
| involved | in this | case | To | ”personally | know” | means | to have | some | direct | or | persona l | ||||||
| knowledge | or | connection | to the | following | individuals | If | you have | only | heard the | ||||||||
| names | through | media | or | social | media, | for | examp | le, | that is | not | persona | l | knowledge | ||||
| 33a | Do | you | or | does | any | member | of | your | family | or | a | close | friend | persona | lly | know | or |
| have | pas t | or | presen | t | dealings | with | the | Defendant | in | this | case, | Ghislaine | Maxwell, or | ||||
| her | family | members? | |||||||||||||||
| o Yes | Wi\lo | ||||||||||||||||
| 33b | Do | you | or | does | any | member | of your | family | or | a | close | friend | persona | lly | know | or | |
| have | pas t | or | presen | t | dealings | with | Jeffrey | Epstein? | |||||||||
| o Yes | 1:2 / | No | |||||||||||||||
| 33c | Do | you | or | does | any | member | of | your | family | or | a | close | friend | persona | lly | know or | |
| have | pas t | or | presen | t dealin | s | with | the U | .S | Attorney | for | the | Southern | District | of | |||
| New | York, | Damian | the | former | Acting | U | .S | Attorney | for the | Southern | |||||||
| District | of | New | York, | Audrey | Strauss, | or | anyone | else who | works | for | or used | to | |||||
| work | for | the | U .S | Attorney’s | Office | for | the | Southern | District of | New | York? | ||||||
| o | Yes | ta / | No | ||||||||||||||
| 33d | Do | you | or | does | any | member | of | your | family | or | a | close | friend | persona | lly | know or | |
| have | pas | t or | presen | t | dealings | with | any | of the | Assistant | United | States | Attorneys | who | ||||
| are | prosecu | ting | this case: | ||||||||||||||
| Maurene | Comey | a Yes | sa / | No | |||||||||||||
| Alison | Moe | o Yes | si | No | |||||||||||||
| Lara | Pomerantz | o Yes | ci | No | |||||||||||||
| Andrew | Rohrbach | o Yes | cr i | No |
Juror ID: gq _¶
| 33e | Do | you | or | does | any | member | of | your | family | or | a | close | friend | persona | lly | know | or |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| have | pas t or | presen | t | dealings | with | any of | the | defense | attorneys | or | law | fi rms | who are | ||||
| represen | ting | the | Defendant: | ||||||||||||||
| Christian | Everdell | of | & | Gresser | LLP | a Yes | o/No | ||||||||||
| Jeffrey | Pagliuca | of | Haddon, | and | , | P .C | o | Yes | o/No | ||||||||
| Laura | Menninger | of | Haddon, | and | , P .C | o | Yes g | /No | |||||||||
| Bobbi | Sternheim | of Law | Offices | of | Bobbi | C | Sternheim | a | Yes | pro | |||||||
| 33E | Do | you or | does | any | member | of | your | family | or a | close | friend | persona | lly | know | or | ||
| have | pas t | or presen | t | dealings | with | the | United | States | District | Court | Judge | who is | |||||
| pres | iding | over | this | case, | Alison | J | Nathan, | or | anyone | who | works | on her | staff? | ||||
| o | Yes | ||||||||||||||||
| 33g | If | you | answered | ”yes” | to | any | of | the above | sub | -ques | tions | (33a, | 33b, 33c, | 33d, | 33e, | ||
| or | 330, | p | lease | exp | lain | whom | you | know, | how | you | know the | individual(s), | and | ||||
| whether | your | relationship | with | that | person | might | make | it | difficult | for | you | to be a | |||||
| fair | and | impartial | juror in | this | case: |
| ------------------------------ | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | |
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:
|¶
| 36 | Based | on | any thing | that | you | have | read, | seen, or | heard | about | Ms | Maxwell, | including | |||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| any | thing | about | criminal | charges | aga | inst | Ms | Maxwell, | have | you | formed | any | ||||
| op | inions | about | Ms | Maxwell | that | might | make | it difficult | for | you | to be | a | fair and | |||
| impartial | juror in | this | case? | |||||||||||||
| o | s4Qo | o | Unsure | |||||||||||||
| o | t app | licable, | I | have | not | read/seen/heard | about Ms | Maxwell | ||||||||
| 36a | If yes | or | unsure, | p lease | exp | lain | why | it | might | be difficult | for | you | to be | a | fair and | |
| impartial | juror in | this | case: | |||||||||||||
| 37 | Before | today, | had you | read, | seen, | or | heard | any | thing | about | Jeffrey | Epstein? | ||||
| te , | Yes | o | No | o | Unsure | |||||||||||
| 37a | If yes | or | unsure, | p lease | state | what | you | remember | hearing, | and how | or | from | whom | |||
| you | may | have | heard (e | .g , | a | friend, | the | newspaper, | a | website, | social | media) | If you | |||
| heard | about | Mr | Epstein | from | a | media | source, | p lease | identify | the | media | source by | ||||
| S — | kaute | On | .i | rand | ’ | LA | Du fe | , “ | Ile tug | |||||||
| 38 | Have | you | verbally | stated | or | pos | ted | your | op | inion on | social | media | or | online | about | |
| Ms | Maxwell | or | r | Epstein? | ||||||||||||
| O Yes | No | |||||||||||||||
| El Not | app | licable, | I | have | not | read/seen/heard | about Mr | Epstein/Ms | Maxwell | |||||||
| 38a | If | yes, | when and | where | did | you | state or | pos t | your op | inion? |
Juror ID: Li¶
| 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 | 0 No | 0 | 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? | ||||
| a Yes | ❑ No | ❑ Unsure | |||
| o 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 | o | 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 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¶
| 44a | If | yes, p | lease | exp | lain: | ||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 45 | Have | you | or a | family | member | ever | supporte | d, | lobbied, | pe | titioned, | pro | tested, or | ||
| worked | in | any | other | manner | for | or aga | inst | any laws, | regu | lations, | or organ | izations | |||
| relating | to | sex | trafficking, | sex | crimes | aga inst | minors, | sex abuse, | or | sexual | |||||
| o Yes | to No | ||||||||||||||
| 45a | If | yes, | p lease | exp | lain 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, | p | lease exp | lain: | ||||||||
| 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 | ”2/No | ||||||||||||||
| 46a | If yes, | p | lease | exp | lain: |
| 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: | _____ |
| BASIC | LEGAL | PRINCIPLES | AND | MEDIA | RESTRICTIONS | ||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 10 Under | the | law, | the | facts | are | for the | jury | to determine | and | the | law is | for | the Judge | to | |||
| determine | You | are | requ | ired | to 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? | ||||||||
| ‘14 | Yes | ❑ | No | ||||||||||||||
| 10a If no, | please | explain: | |||||||||||||||
| 11 The | law | prov | ides | that | a | defendant | in | a | criminal | case | is | presume | d | innocent | at | all | |
| stages | of | the | trial | and | is | not | requ | ired | to | put on | any | defense | at | all | The Government | ||
| is requ | ired | to | prove | the | defendant | gu | ilty | beyond | a | reasonable | doubt | on | each | charge | |||
| Do | you | accept | these | principles, | and | will | you | be able | to | apply | them | if selected | to | ||||
| serve | on | this | jury? | ||||||||||||||
| X | Yes | ❑ | No | ||||||||||||||
| 11 a If | no, please | explain: |
Juror ID: 5 °¶
| 12 | The | law | prov | ides | that a defendant in a criminal case has an absolute right not to | |
|---|---|---|---|---|---|---|
| testify, | and | that | a | juror cannot hold it aga inst the defendant if she chooses not to | ||
| testify | Do | you | accep | t this pr inciple, and will you be able to app ly it if selected to | ||
| serve | on | this | jury? | |||
| )(Yes ❑ No | ||||||
| 12a | If | no, | p lease | exp | lain: | |
| 13 | A | juror | is requ | ired | by law to make his or her decision based solely on the evidence | |
| or | lack | of evidence | presen ted in Court, and not on the basis of conjecture, susp icion, | |||
| bias, | sympa | thy, | or prejudice Do you accep t this pr inciple, and will you be able to | |||
| app | ly | it | if selected | to serve on this jury? | ||
| S Yes ❑ No | ||||||
| 13a | If | no, | p | lease | exp | lain: |
| 14 | Under | the | law, | the ques tion of pun ishment is for the Court alone to decide, and thus | ||
| the | issue | of | pun | ishment must not enter into your deliberations as to whether the | ||
| defendant | is gu | ilty or not gu ilty as charged Do you accep t this pr inciple, and will | ||||
| you | be | able | to | app ly it if selected to serve on this jury? | ||
| Yes ❑ No | ||||||
| 14a | If | no, | p lease | exp | lain: |
| 15 You | may | hear | testimony | in this | case that | law | enforcement | officers | recovered | certain | |||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| evidence | from | searches | The Court | will | instruct | you that | those | searches | were legal | ||||
| and | that | the | evidence | obtained | from those | searches | is | admissible | in | this case | Do | ||
| you | have | any | feelings | or | op inions | about | searches | conducted | by | law | enforcement | ||
| officers, | or the | use | of | evidence | obtained | from | searches, | that | would | affect | your | ||
| ability | to | be | fair and | impartial in | this | case? | |||||||
| ❑ Yes | X No | ||||||||||||
| 15a If | yes, p | lease | exp | lain: | |||||||||
| 16 You | also | may | hear | testimony | in | this | case | from | expert | witnesses | Have you | had any | |
| exper | iences | with | experts, | or do | you | have any | genera l | feelings | about | the | use of | ||
| experts, | that | would | affect | your | ability | to be | fair | and | impartial | in this | case? | ||
| ❑ Yes | XNo | ||||||||||||
| 16a If | yes, | p lease | exp | lain: | |||||||||
| 17 As | instructed | above, | from now | and | until | your | jury | service | is comp | lete, | you are | ||
| instructed | to | avoid | all | media | coverage | and | not | to go | on the | Internet | with | regar d to | |
| this | case for | any | purpose | That | is, you | are | forbidden | from | consuming | any | news | ||
| media | or | social | media, | or any | discussion | of | this | case | (or of | anyone | participating in | ||
| the case) | outside | of the | courtroom | whatsoever | You | also must | not | discuss | this case | ||||
| with | anyone | This | includes | your | family, | friends, | spouse, | domestic | partner, | ||||
| colleagues, | and co | -workers | These | instructions | app ly | from | now and | until | you are | ||||
| either | dismissed | from | jury | selection | or | chosen | as a | juror and | the | trial is | comp lete | ||
| When | we | return | for the | next | step in | jury | selection, | the | Judge | will | ask you | if you | |
| have | followed | this | instruction | ||||||||||
| Do you | have | any | reservations | or | concerns | about | your | ability | or | willingness | to | ||
| follow | this | instruction? | |||||||||||
| ❑ | Yes | ’No |
| 17a. | If yes, please explain: | |
|---|---|---|
| ------ | ------------------------- | ------------------------------------------- |
| --------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 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 |
| 21a | If | yes, | is | there | any | thing | about | that | exper | ience | that | would | preven | t | you | from | acting | as |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| a | fair | and | impartial | juror | in | this | case? | |||||||||||
| o | Yes | o No | ||||||||||||||||
| 21b | If | yes | to | 21a, | p | lease | exp lain: | |||||||||||
| 22 | Have | you, | or | has | any | relative | or | close | friend, | ever | been | subpoenaed | for | any | inquiry | |||
| or | investigation? | |||||||||||||||||
| ❑ | Yes | (self) | ❑ | Yes | (friend | or | family | member) | )1 1 4 / | No | ||||||||
| 22a | If yes, | is there | any | thing | about that | exper | ience | that would | preven | t you | from | acting as | ||||||
| a | fair | and | impartial | juror in | this | case? | ||||||||||||
| ❑ | Yes | o No | ||||||||||||||||
| 22b | If | yes to | 22a, | p | lease | exp lain: | ||||||||||||
| 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) | No | ||||||||||
| 23a | If | yes, | is | there | any | thing | about | that | exper | ience | that | would | preven | t | you | from | acting as | |
| a | fair | and | impartial | juror | in this | case? | ||||||||||||
| ❑ Yes | ❑ | No | ||||||||||||||||
| 23b | If | yes | to | 23a, p | lease | exp | lain: |
| 24 Have | you, | or has | any | relative | or | close | friend, | ever | been | the | subject | of any | |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| investigation | or | accusation | by | any gran | d jury, | state or | federal, | or any | other | ||||
| o | Yes | (self) | a Yes | (friend | or | family | member) | )(No | |||||
| 24a If yes, | is | there | any thing | about | that exper | ience | that | would | preven | t | you from acting as | ||
| a fair | and | impartial | juror | in this | case? | ||||||||
| o | Yes | o | No | ||||||||||
| 24b If yes | to | 24a, p | lease | exp | lain: | ||||||||
| 25 Have | you, | or | any of | your | relatives | or | close | friends, | ever | been | a | victim of a crime? | |
| o Yes | (self) | o | Yes | (friend | or | family | member) | XNo | |||||
| 25a If yes, | is | there | any | thing | about | that | exper | ience | that | would | preven | t | you from acting as |
| a fair | and | impartial | juror | in this | case? | ||||||||
| o | Yes | o | No | ||||||||||
| 25b If | yes to | 25a, p | lease | exp | lain: | ||||||||
| 26 Have | you, | or | has any | member | of your | family | or any | of | your | close | friends —either as | ||
| individuals | or | in the | course | of | their | business | affairs | —ever | been a | party to a legal | |||
| action | or | dispute | with | the | United | States, | or with | any | of | the | officers, | departments, | |
| agenc | ies, | or | emp | loyees | of the | United | States, | including | the | United | States Attorney’s | ||
| Office, | the | FBI, or | the | NYPD? | |||||||||
| o | Yes | (self) | o | Yes | (friend | or | family | member) | 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:¶
| |¶
| ------ | ----------------------------------------------------- |
|---|
| PERSONAL | RELATIONSHIP | WITH | CASE | PARTICIPANTS | |||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 33 | The | next | subset | of | ques | tions asks | whether | you | or | any | member | of | your | family | or a | ||
| close | friend | persona | lly | knows | or has | pas t | or | presen | t | dealings | with | individuals | |||||
| involved | in this | case | To | ”persona | lly | know” | means | to have | some | direct | or | personal | |||||
| knowledge | or | connection | to the | following | individuals | If | you have | only | heard | the | |||||||
| names | through | media | or | social | media, | for | examp | le, | that is | not | personal | knowledge | |||||
| 33a | Do | you | or | does | any | member | of | your | family | or | a | close | friend | persona | lly | know | or |
| have | pas t | or | presen | t dealings | with | the | Defendant | in | this | case, | Ghislaine | Maxwell, or | |||||
| her | family | members? | |||||||||||||||
| o Yes | X | No | |||||||||||||||
| 33b | Do you | or | does | any | member | of | your | family | or | a | close | friend | persona | lly | know | or | |
| have | pas t | or | presen | t | dealings | with | Jeffrey | Epstein? | |||||||||
| o Yes | X | No | |||||||||||||||
| 33c | Do | you | or | does any | member | of your | family | or | a | close | friend | persona | lly | know or | |||
| have | pas | t or | presen | t | with | the U | .S | Attorney | for | the | Southern | District | of | ||||
| New | York, | Damian,the | former | Acting | U | .S | Attorney | for the | Southern | ||||||||
| District | of | New | York, | Audrey | Strauss, | or | anyone | else who | works | for | or | used to | |||||
| work | for | the | U .S | Attorney | ’s | Office | for | the | Southern | District of | New | York? | |||||
| o | Yes | I X | No | ||||||||||||||
| 33d | Do | you | or | does | any | member | of | your | family | or | a | close | friend | persona | lty | know or | |
| have | pas | t or | presen | t | dealings | with | any | of the | Assistant | United | States | Attorneys who | |||||
| are | prosecu | ting | this case: | ||||||||||||||
| Maurene | Comey | o Yes | )(No | ||||||||||||||
| Alison | Moe | o Yes | X | No | |||||||||||||
| Lara | Pomerantz | o Yes | X | No | |||||||||||||
| Andrew Rohrbach | o Yes | )(No |
Juror ID: 6-0¶
| 33e | Do | you | or | does | any | member | of | your | family | or a | close | friend | persona | lly | know | or | |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| have | pas t | or | presen | t | dealings | with | any of | the | defense | attorneys | or | law | firms | who are | |||
| represen | ting the | Defendant: | |||||||||||||||
| Christian | Everdell | of | BM& | Gresser | LLP | ❑ Yes | g | No | |||||||||
| Jeffrey | Pagliuca | of | Haddon, | and | P .C | ❑ Yes | g | No | |||||||||
| Laura | Menninger | of | Haddon, | and | EMI | P .C | ❑ | Yes | )(No | ||||||||
| Bobbi | Stemheim | of Law | Offices | of | Bobbi | C | Sternheim | ❑ | Yes | X No | |||||||
| 331 | Do | you or | does | any | member of | your | family | or a | close | friend | persona | lly | know | or | |||
| have | pas t | or | presen | t | dealings | with | the | United | States | District | Court | Judge | who is | ||||
| pres | iding | over | this | case, | Alison | J | Nathan, | or | anyone | who | works | on her | staff? | ||||
| ❑ Yes | y | No | |||||||||||||||
| 33g | If | you | answered | ”yes” to | any | of | the above | sub | -ques | tions | (33a, | 33b, 33c, | 33d, | 33e, | |||
| or | 33f), | p | lease | exp | lain | whom | you | know, | how | you | know the | individual(s), | and | ||||
| whether | your | relationship | with | that | person | might | make | it | difficult | for | you | to be a | |||||
| fair | and | impartial | juror | in this | case: |
| ------------------------------ | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | |
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
If yes or unsure, please summarize your opinion:
|¶
| 36 | Based | on | any thing | that | you | have | read, | seen, | or | heard | about | Ms | Maxwell, | including | ||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| any | thing | about | criminal | charges | aga | inst | Ms | Maxwell, | have | you | formed | any | ||||
| op | inions | about Ms | Maxwell | that | might | make it | difficult | for | you to | be | a fair | and | ||||
| impartial | juror in | this | case? | |||||||||||||
| o Yes | YkNo | o | Unsure | |||||||||||||
| o Not | app | licable, | I | have | not | read/seen/heard | about Ms | Maxwell | ||||||||
| 36a | If yes | or | unsure, | p lease | exp | lain | why | it | might be | difficult | for | you | to be | a | fair and | |
| impartial | juror in | this | case: | |||||||||||||
| 37 | Before | today, | had you | read, | seen, | or | heard | any | thing | about | Jeffrey | Epstein? | ||||
| X | Yes | o | No | o | Unsure | |||||||||||
| 37a | If | yes or | unsure, | p lease | state | what | you | remember | hearing, | and how | or | from | whom | |||
| you | may | have | heard (e | .g ., | a | friend, | the | newspaper, | a | website, | social | media) | If you | |||
| heard | about | Mr | Epstein | from | a media | source, | p lease | identify | the | media | source by | |||||
| CO | N | I S | 50A,CC | te, | \ e_ | and | &GOA | VC .%5 | afecfrh | |||||||
| 0 | 06‘ , | ‘tAput | 1 | .L | V | -iM | IN | )(AA | GkAttckAn8 | t( | 1Cill | |||||
| 38 | Have | you | verbally | stated | or | pos | ted | your | op | inion on | social | media | or | online | about | |
| Ms | Maxwell | or Mr | Epstein? | |||||||||||||
| O | Yes | )1(No | ||||||||||||||
| O | Not app | licable, | I | have | not | read/seen/heard | about Mr | Epstein/Ms | Maxwell | |||||||
| 38a | If | yes, | when | and where | did | you | state | or pos t | your op | inion? |
Juror ID: 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: | _____ | _____ |
| BASIC | LEGAL | PRINCIPLES | AND | MEDIA | RESTRICTIONS | ||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 10 | Under | the | law, | the facts | are | for the | jury | to | determine | and the | law is | for the | Judge to | ||
| determine | You | are | requ | ired | to accept | the | law as | the | Judge exp | lains it | to | you even if | |||
| you | do | not like | the | law | or | disagree | with | it, | and you | must | determine | the facts | |||
| according | to | those | instructions | Do | you | accept | this | pr | inciple, | and will | you | be able to | |||
| follow | the | Judge’s | instructions | if | selected | to | serve | on | this jury? | ||||||
| VYes | a No | ||||||||||||||
| 10a If | no, | p | lease | exp lain: | |||||||||||
| 11 | The | law | provides | that | a | defendant | in a | criminal | case is | presumed | innocent | at all | |||
| stages | of | the | trial | and | is not | requ ired | to | put | on any | defense | at | all The | Government | ||
| is | requ | ired | to | prove | the | defendant | gu | ilty | beyond a | reasonable | doubt on | each | charge | ||
| Do | you | accept | these | pr | inciples, | and | will | you | be | able to | app ly | them if | selected | to | |
| serve | on | this | jury? | ||||||||||||
| le | Yes | o | No | ||||||||||||
| I la If | no, | p | lease | exp lain: |
Juror ID: -1-th¶
| 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 aga | inst | the | defendant | if she | chooses | not | to | |||
| testify | Do you | accept | this | pr | inciple, | and | will | you | be | able to | app | ly it if | selected | to | ||
| serve on | this | jury? | ||||||||||||||
| h(Yes | o No | |||||||||||||||
| 12a | If | no, p | lease | exp lain: | ||||||||||||
| 13 | A | juror | is requ | ired | 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, | susp | icion, | ||
| bias, | sympathy, | or | prejudice | Do you | accept | this | pr inciple, | and | will you | be | able to | |||||
| app | ly it | if | selected to | serve | on | this | jury? | |||||||||
| 1lYes | o | No | ||||||||||||||
| 13a | If | no, p | lease | exp lain: | ||||||||||||
| 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 gu | ilty or | not | gu ilty | as | charged | Do you | accept | this pr | inciple, | and | will | ||||
| you | be | able to | app ly | it if | selected | to | serve | on | this | jury? | ||||||
| Is / | Yes | o | No | |||||||||||||
| 14a | If no, | p | lease exp | lain: |
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¶
| 21a | If | yes, | is | there | anything | about that experience that would prevent you from acting as | ||
|---|---|---|---|---|---|---|---|---|
| a | fair | and | impartial | juror in this case? p i A | ||||
| o | Yes o No | |||||||
| 21b | If | yes to | 21a, | p | lease | exp | lain: | |
| 22 | Have | you, | or | has | any | relative or close friend, ever been subpoenaed for any inquiry | ||
| or | investigation? | |||||||
| o | Yes | (self) | o Yes (friend or family member) 8/No | |||||
| 22a | If | yes, | is | there | anything | about that experience that would prevent you from acting as | ||
| a | fair | and | impartial | juror | in this case? Nip | |||
| o | Yes o No | |||||||
| 22b | If | yes | to | 22a, | p | lease | exp | lain: |
| 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) ‘No | |||||
| 23a | If | yes, | is | there | anything | about that experience that would prevent you from acting as | ||
| a | fair | and | impartial | juror | in this case? MA | |||
| 0 | Yes o No | |||||||
| 23b | If | yes | to | 23a, | p | lease | exp | lain: |
| 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¶
| 26a | If | yes, | is | there | anything | about | that | experience | that | would | prevent | you | from | acting | as |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| a | fair | and | impartial | juror in | this case? | ( 1 4 / ., 1)1 fl | |||||||||
| o | Yes | ci No | |||||||||||||
| 26b | If | yes | to | 26a, | p lease | exp lain: | |||||||||
| 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? | |||||||
| o | Yes | (self) | o | Yes | (friend | or family | member) | ii 7 | /%1 o | ||||||
| 27a | If | yes, | is | there | anything | about | that | experience | that | would | prevent | you | from | acting | as |
| a | fair | and | impartial | juror | in | this case? | N/il | ||||||||
| o | Yes | a No | |||||||||||||
| 27b | If | yes | to 27a, | p lease | exp 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 personally | know or |
|---|---|---|
| Christian Everdell of= | & Gresser LLP o Yes 6/ No | |
| Jeffrey Pagliuca of Haddona | anda, P.C. o Yes eiNo | |
| Laura Menninger of Haddon | ma, P.C. o Yes vi No | |
| 33f. | Do you or does any member of your family or a close friend personally | know or |
| o Yes | trNo | |
| 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: _____ |
| 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 personally | know or |
|---|---|---|
| Christian Everdell of an& | Grosser LLP ❑ Yes a No | |
| Jeffrey Pagliuca of Haddon, | and P.C. ❑ Yes AP No | |
| Laura Menninger of Haddon, and | P.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 personally | know or |
| ❑ Yes | of 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:
|
| 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 |
|---|---|
| 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 |
| 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 |
| 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 Have | you, | or | has any | relative | or close | friend, | ever | been | the | subject | of any | ||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| investigation | or | accusation | by | any gran | d | jury, | state | or | federal, | or any | other | ||
| a Yes | (self) | o | Yes (friend | or | family | member) | Ni No | ||||||
| 24a If yes, | is | there | any | thing | about | that exper | ience | that | would | preven | t | you from acting as | |
| a fair | and | impartial | juror | in this | case? | ||||||||
| o | Yes | a | No | ||||||||||
| 24b If | yes to | 24a, p | lease | exp | lain: | ||||||||
| 25 Have | you, | or | any of | your | relatives | or | close | friends, | ever | been | a vi | im of a crime? | |
| o Yes | (self) | a | Yes | (friend | or | family | member) | No | |||||
| 25a If | yes, is | there | any | thing | about | that | exper | ience | that | would | preven | t | you from acting as |
| a | fair and | impartial | juror | in this | case? | ||||||||
| o | Yes | a | No | ||||||||||
| 25b If | yes to | 25a, | p lease | exp | lain: | ||||||||
| 26 Have | you, | or | has any | member | of your | family | or any | of | your | close | friends —either as | ||
| individuals | or | in the | course | of | their | business | affairs | —ever | been | a | par ty to a legal | ||
| action or | dispute | with | the | United | States, | or with | any | of | the | officers, | departments, | ||
| agenc | ies, | or | emp | loyees | of the | United | States, | including | the | United | States Attorney’s | ||
| Office, | the FBI, | or | the | NYPD? | |||||||||
| o | Yes | (self) | a | Yes | (friend | or | family | member) | 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 | No | |||||||||||||||||||||||
| Alison Moe | Yes | No | |||||||||||||||||||||||
| Lara Pomerantz | Yes | No | |||||||||||||||||||||||
| Andrew Rohrbach | Yes | No |
Juror ID: //y¶
| 33e Do | you | or | does | any | member | of | your | family | or a | close | friend | nal | know or | |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| have pas | t or | presen | t | dealings | with | any | of the | defense | attorneys | or | law | \ rms ei who are | ||
| represen | ting | the | Defendant: | |||||||||||
| Christian | Everdell | of | & | Gresser | LLP | o | \ | No | ||||||
| Jeffrey | Pagliuca | of | Haddon, | and | , P .C | o | Y | No | ||||||
| Laura | Menninger | of | Haddon, | and | , P | .C | a | Yee No | ||||||
| Bobbi | Stemheim | of | Law | Offices | of | Bobbi | C | Stemheim | o Yes | No | ||||
| 33f. Do | you | or | does | any | member | of | your | family | or a | close | friend | persona | lly | know or |
| have pas | t or | presen | t | dealings | with | the | United | States | District | Court | Judge | who is | ||
| pres | iding | over | this case, | Alison | J | Nathan, | or | anyone | who | works on | her | staff? | ||
| o | Yes | No | ||||||||||||
| 33g If | you | answered | ”yes “ | to any | of | the | above | sub -ques | tions | (33a, | 33b, | 33c, | 33d, 33e, | |
| or | 330, | p lease | exp | lain | whom | you | know, | how | you | know | the | individual(s), | and | |
| whether | your | relationship | with | that | person | might | make | it | difficult | for | you to be a | |||
| fair and | impartial | juror | in | this case: |
Juror ID: / /¶
| KNOWLEDGE | OF CASE | AND | PEOPLE | |||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| This | case | has | been | widely | repor | ted | in the | national | and | local | media | There is | ||||
| nothing | wrong | with | having | heard | something | about | this | case It | is | important to | ||||||
| answer | all | of | the | following | ques | tions | truthfully | and | fully | |||||||
| 34 | Before | today, | had | you | read, | seen, | or | heard any | thing | about Ms | Maxwell? | |||||
| NI | Yes | o | No | o | Unsure | |||||||||||
| 34a | If yes | or | unsure, | p | lease | state | what | you | remember | hearing, | and | how | or | from | whom | |
| you | may | have | heard | (e .g | , a | friend, | the | newspaper, | a | website, | social | media) | If you | |||
| heard | about | Ms | Maxwell | from | a | media | source, | p lease | identify | the | media | source by | ||||
| Ns | I | lt h ” ( | WM | :1 | , | 9da”? | g 75 | im , 4 | z E / | .94 e | A l | |||||
| ect | 0 | 7 | V | nemis | 7 | r oi | r | ci rn | crccOe | ,q41 | ea | ) ti t | ||||
| /17 1 | , | Efsie;n, | ||||||||||||||
| 35 | Have | you | persona | lly | formed | an op | inion about | Ms | Maxwell’s | gu | ilt | or | innocence of | |||
| the | crimes | charged | as a | result | of | any | thing | you have | heard, | read or | seen? | |||||
| o | Yes | NEI | No | o Unsure | ||||||||||||
| o | Not | app | licable, | I | have not | read/seen/heard | about | Ms | Maxwell | |||||||
| 35a | If | yes or | unsure, | p | lease | summarize | your op | inion: |
| 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 |
|---|---|
| 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 |
| 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 |
| ------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 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] |
| 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, | acqua intance, | |||||
| superv | isor, | teacher, | or | family | member | .) | ||||||||
| o | Yes | (self) | o | Yes | (friend | or | family | member) | -tl No | |||||
| 49a If | yes, | without | listing | names | p lease | exp | lain: | |||||||
| 49b If | your | answer to | 49 was | yes, | do | you | believe | that | this | would | affect | your ability to | ||
| serve | fairly | and | impartially | as | a juror | in | this | case? | ||||||
| o Yes | o | No | ||||||||||||
| 49c If | yes | to | 49b, p lease | exp | lain: | |||||||||
| 50 | Is | there any | other | exper | ience | that | you | or | anyone | close | to | you | has | had that may |
| affect | your | ability | to serve | fairly | and | imps | ’ally | as | a juror | in | this | case? | ||
| o Yes | No | |||||||||||||
| 50a | If yes, | p | lease exp | lain: |
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: |
| 12 | The | law | prov | ides | that a defendant in a criminal case has an absolute right not to | |
|---|---|---|---|---|---|---|
| testify, | and | that | a juror cannot hold it aga inst the defendant if she chooses not to | |||
| testify | Do | you | accep t this pr inciple, and will you be able to app ly it if selected to | |||
| serve | on | this | jury? | |||
| 1 9 Yes o No | ||||||
| 12a | If | no, | p | lease | exp | lain: |
| 13 | A | juror | is requ | ired | by law to make his or her decision based solely on the evidence | |
| or | lack | of evidence | presen ted in Court, and not on the basis of conjecture, susp icion, | |||
| bias, | sympa | thy, | or prejudice Do you accep t this pr inciple, and will you be able to | |||
| app | ly | it | if | selected | to serve on this jury? | |
| itIOYes o No | ||||||
| 13a | If | no, | p | lease | exp | lain: |
| 14 | Under | the | law, | the ques tion of pun ishment is for the Court alone to decide, and thus | ||
| the | issue | of | pun | ishment must not enter into your deliberations as to whether the | ||
| defendant | is gu | ilty or not gu ilty as charged Do you accep t this pr inciple, and will | ||||
| you | be | able | to | app ly it if selected to serve on this jury? | ||
| ap Yes o No | ||||||
| 14a | If | no, | p | lease | exp | lain: |
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.
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