Browse by Document Type
Other (98,409 documents)
Case 1:20-cr-00330-PAE Document 365 _ Filed 10/22/21 Page 30 of 40
Juror ID:
-29-
DOJ-OGR-00005306
Case 1:20-cr-00330-PAE Document 365 _ Filed 10/22/21 Page 25 of 40
Juror ID:
46-47] Witnesses in this case may testify claiming sexual abuse or sexual assault. Would
you have any difficulty assessin
Case 1:20-cr-00330-PAE Document 365 _ Filed 10/22/21 Page 26 of 40
Juror ID:
48.49] Have you or a friend or family member ever been accused of sexual harassment,
sexual abuse, or sexual assault? (Th
Case 1:20-cr-00330-PAE Document 365 _ Filed 10/22/21 Page 28 of 40
Juror ID:
DECLARATION
I, Juror Number declare under penalty of perjury that the foregoing answers set forth in
this Jury Questionna
Case 1:20-cr-00330-PAE
Document 365
Filed 10/22/21 Page 27 of 40
Juror ID:
CLOSING QUESTION
Do you wish for any particular answers to remain confidential and to not go beyond
the Judge, counsel,
Case 1:20-cr-00330-PAE Document 365 _ Filed 10/22/21 Page 22 of 40
Juror ID:
38.39] Based on anything that you have read, seen, or heard about Jeffrey Epstein, have
you formed any opinions about Mr.
Case 1:20-cr-00330-PAE Document 365 _ Filed 10/22/21 Page 23 of 40
Juror ID:
40a If no or unsure, please explain:
la
NATURE OF CHARGES
44.42! During the trial, you will hear evidence alleging sex
Case 1:20-cr-00330-PAE Document 365 _ Filed 10/22/21 Page 24 of 40
Juror ID:
Aged If yes, please explain:
Aa.
44.45| Have you or a family member ever supported, lobbied, petitioned, protested, or
w
Case 1:20-cr-00330-PAE
Document 365
Filed 10/22/21 Page 21 of 40
Juror ID:
35.36 Based on anything that you have read, seen, or heard about Ms. Maxwell, including
anything about criminal charges a
Case 1:20-cr-00330-PAE Document 365 _ Filed 10/22/21 Page 20 of 40
Juror ID:
KNOWLEDGE OF CASE AND PEOPLE
This case has been widely reported in the national and local media. There is
nothing wrong
Case 1:20-cr-00330-PAE Document 365 _ Filed 10/22/21 Page 15 of 40
Juror ID:
25.a-2| If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror
Case 1:20-cr-00330-PAE Document 365 _ Filed 10/22/21 Page14 of 40
Juror ID:
23.24 Have you, or has any relative or close friend, ever been the subject of any
investigation or accusation by any grand
Case 1:20-cr-00330-PAE Document 365 _ Filed 10/22/21 Page11 of 40
Juror ID:
You may hear testimony in this case that law enforcement officers recovered certain
evidence from searches. The Court will
Case 1:20-cr-00330-PAE Document 365 _ Filed 10/22/21 Page 12 of 40
Juror ID:
16a-1| If yes, please explain:
PRIOR JURY SERVICE
4418 Have you ever served as a juror in a trial in any court?
Yes No
4
Case 1:20-cr-00330-PAE Document 365 _ Filed 10/22/21 Page 10 of 40
Juror ID:
44.12! The law provides that a defendant in a criminal case has an absolute right not to
testify, and that a juror cannot
Case 1:20-cr-00330-PAE Document 365 _ Filed 10/22/21 Page 9 of 40
Juror ID:
8.9. Do you have any religious, philosophical, or other beliefs that would make you
unable to render a verdict in a crimina
Case 1:20-cr-00330-PAE Document 365 Filed 10/22/21 Page 8 of 40
Juror ID:
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,
Case 1:20-cr-00330-PAE Document 365 _ Filed 10/22/21 Page4of40
Juror ID:
PRELIMINARY INSTRUCTIONS
Please read the following instructions carefully before completing any portion of this
questionnair
Case 1:20-cr-00330-PAE Document 365 _ Filed 10/22/21 Page5of40
Juror ID:
Your name will not be disclosed or connected to this questionnaire beyond the Judge and the
parties in this case. However, if
Case 1:20-cr-00330-PAE Document 365 _ Filed 10/22/21 Page 7 of 40
Juror ID:
PLEASE ANSWER THE FOLLOWING QUESTIONS:
ABILITY TO SERVE
Please note: In the event you are excused from service on this j
Case 1:20-cr-00330-PAE Document 365 _ Filed 10/22/21 Page 6 of 40
Juror ID:
SCHEDULE
Potential jurors will be called back for further questioning and jury selection from
Tuesday, November 16, 2021,
Case 1:20-cr-00330-PAE Document 365 Filed 10/22/21 Page 3 of 40
Juror ID:
INSERT JUROR INFORMATION SHEET FROM JURY DEPARTMENT
DOJ-OGR-00005279
Case 1:20-cr-00330-PAE Document 364 _ Filed 10/22/21 Page2of3
o Lists for questionnaires completed on November 4 and 5 will be due to the Court
via email by November 7.
o Lists for questionnaires com
Case 1:20-cr-00330-PAE Document 364 _ Filed 10/22/21 Page3of3
28, 81, 95, 99, 101, 232, 241, 284, 301, 315, the defense did not justify sealing the entirety of the
proposed and draft questionnaires a
Case 1:20-cr-00330-PAE Document 362 Filed 10/20/21 Page3of4
Post, No. 92-301, 1992 WL 233354, at *2 (D.D.C. July 23, 1992); Copley Press, Inc. v. Superior
Court, 228 Cal. App. 3d 77, 89 (1991).
The
Case 1:20-cr-00330-PAE Document 362 Filed 10/20/21 Page2of4
with benefits to both the defendant and to society as a whole.”).
Voir dire is a critical stage of criminal proceedings, and the public in
Case 1:20-cr-00330-PAE
Document 362
Filed 10/20/21 Page4of4
Washington, DC 20005
(202) 795-9300
[email protected]
The Miami Herald
American Broadcasting Companies, Inc.
The Center for Investigat
Case 1:20-cr-00330-PAE Document 360 Filed 10/19/21 Page2of2
Dated: October 19, 2021 A \) it
New York, New York
ALISON J. NATHAN
United States District Judge
DOJ-OGR-00005267
Case 1:20-cr-00330-PAE Document 357
Filed 10/18/21
Certificate of Service
Page 4 of 4
I hereby certify that on October 18, 2021, I electronically filed the foregoing Defendant
Ghislaine Maxwell's
Case 1:20-cr-00330-PAE Document 357 _ Filed 10/18/21 Page3of4
Respectfully submitted,
s/ Jeffrey S. Pagliuca
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Ave
Case 1:20-cr-00330-AJN Document 356 Filed 10/18/21 Page 1 of 1
LAW OFFICES OF BOBBI C. STERNHEIA\
212-243-1100 * Main 225 Broadway, Suite 715
917-912-9698 ° Cell New York, NY 10007
888-587-4737 ° Fa
Case 1:20-cr-00330-PAE Document 355 Filed 10/18/21 Page2of5
Page 2
292 F.3d at 128; see also United States v. Kyles, 40 F.3d 519, 524 (2d Cir. 1994) (stating that a
district court has “broad discret
Case 1:20-cr-00330-PAE Document 355 _ Filed 10/18/21 Page3of5
Page 3
defendant claims that because this case has received significant pretrial publicity and the charges
involve a “sensitive subject
Case 1:20-cr-00330-PAE Document 355 _ Filed 10/18/21 Page4of5
Page 4
believe that counsel will be better than the Court at identifying bias, nor that counsel will be more
interested than the Court i
Catach: 220 OCkKBP AEN DunumentS Aiitel1001E201 Pateye Gfof 4
Page 3
“Given that the hearing provides an opportunity for the Rule 412 movant to detail the evidence he
seeks to admit and for the part
Caash: 220 OCKBP AEN DunumentS Aiitel1001E201 Pateyé dfof 4
Page 4
of them, there may be a need for multiple such hearings. The Court must then adjudicate the
motion before trial starts or during tr
Caash: 220 OCkKBP AEN DunumentSao Ate 1001E21 Pateye afat 3
Page 2
standard procedures for legal mail, and these protocols apply to each one of the approximately
1,700 inmates at the MDC. Legal coun
Cash: 22OrOCKBP AEN DunumentSao Aiitel1001E201 Pateye Gfaf 3
Page 3
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
By: ___s/
Alison Moe
Lara Pomerantz
Andrew Rohrbach
Assistant Uni
Case 1:20-cr-00330-PAE Document 352 Filed 10/15/21 Pagelof2
LAW OFFICES OF BOBBI C. STERNHEIA\
212-243-1100 * Main 225 Broadway, Suite 715
917-912-9698 * Cell New York, NY 10007
888-587-4737 ° Fax b
Case 1:20-cr-00330-PAE Document 352 Filed 10/15/21 Page2of2
LAW OFFICES OF BOBBI C. STERNHEIA\
It is time for the Government and the Court to seriously reconsider Ms. Maxwell’s
detention. This situat
Case 1:20-cr-00330-PAE Document 351 Filed 10/15/21 Page3of4
Page 3
“Given that the hearing provides an opportunity for the Rule 412 movant to detail the evidence he
seeks to admit and for the partie
Case 1:20-cr-00330-PAE Document 350 Filed 10/15/21 Page2of3
Page 2
standard procedures for legal mail, and these protocols apply to each one of the approximately
1,700 inmates at the MDC. Legal coun
Case 1:20-cr-00330-PAE Document 346 Filed 10/14/21 Page3of3
LAW OFFICES OF BOBBI C. STERNHEIA\
to believe that Ms. Maxwell’s ability to defend and prepare for trial will continue to be severely
compr
Case 1:20-cr-00330-PAE Document 345 Filed 10/14/21 Page2of3
The Honorable Alison J. Nathan
October 14, 2021
Page 2
Ms. Maxwell’s counsel conferred with the government about the timing for filing a
m
Case 1:20-cr-00330-PAE Document 345 Filed 10/14/21 Page3of3
The Honorable Alison J. Nathan
October 14, 2021
Page 3
her counsel cannot adequately consult with her about the defense. Allowing Ms. Maxwel
Case 1:20-cr-00330-PAE Document 344 Filed 10/14/21 Page2of2
Dated: October 14, 2021 MM \) if
New York, New York
ALISON J. NATHAN
United States District Judge
DOJ-OGR-00005225
Case 1:20-cr-00330-PAE Document 342 Filed 10/13/21 Page16of17
This application is not seeking to conduct unduly invasive questioning, to “pre-try” the
case to the venire, to create impressions or sym
Case 1:20-cr-00330-PAE Document 342 Filed 10/13/21 Page17of17
Considering the sensitive nature of the charges and the pervasive pretrial publicity and
exposure of this case, the Court should grant th
Case 1:20-cr-00330-PAE Document 342 Filed 10/13/21 Page15of17
admissions of bias on the part of jurors.* In-depth voir dire including limited open-ended
questions posed by counsel also helps to attac
Case 1:20-cr-00330-PAE Document 342 Filed 10/13/21 Page14of17
for the court's evaluation, ‘merely going through the form of obtaining jurors’ assurances of
impartiality is insufficient [to test that