{
  "document_metadata": {
    "page_number": "15",
    "document_number": "367-1",
    "date": "10/22/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 367-1 Filed 10/22/21 Page 15 of 17 58. Do you have any difficulty with your sight or hearing that could affect your ability to see or hear what happens during the trial? 59. Do you have any difficulty understanding, reading, or speaking the English language? 60. Have you or has anyone close to you ever been charged with a crime? 61. Have you or anyone close to you ever been accused of sexual assault or sexual harassment? 62. Have you or has anyone close to you ever been the victim of a crime? [Yes/Unsure question privately] 63. Have you or has anyone close to you ever been the victim of a sexual crime? [Yes/Unsure question privately] 64. 'Juror's Background' The parties respectfully request that the Court ask each juror to state the following information: (a) the juror's age; (b) the juror's family status (including whether the juror has any children and, if so, ages of the children); (c) the juror's current town of residence and length of time at the residence; (d) the juror's county of residence during the past ten years; (e) the educational background (including the highest degree obtained); (f) the juror's occupation; (g) the name and general location of the juror's employer; and the period of employment (with that employer; (h) the same information concerning other employment within the last five years; 14 Commented [A1]: DEFENDANT. The defense intends to file a motion in limine rather than voir dire on these topics. See United States v. N.C. CaB. 238 (EDN.Y. 2018) (AMD); Elizabeth Holmes (Theranos), 18 F.4th 285, 286 (9th Cir. 2021) (NG); United States v. Robert Kelly, 19 F.4th 204 (2d Cir. 2021) (NG). Proposed Jury Questionnaire. In the most recent high-profile federal cases, the Government objects but it included the very same background information in the written questionnaire. In addition to saying to provide a good faith foundation for conducting research on the jurors to confirm or uncover bias, in longest financial fraud trials in SDNY was veritied in one of the juror due to false information on 'Juror T. F. 20-H-244 (SDNY (2012)). DOJ-OGR-00005372",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 367-1 Filed 10/22/21 Page 15 of 17",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "58. Do you have any difficulty with your sight or hearing that could affect your ability to see or hear what happens during the trial? 59. Do you have any difficulty understanding, reading, or speaking the English language? 60. Have you or has anyone close to you ever been charged with a crime? 61. Have you or anyone close to you ever been accused of sexual assault or sexual harassment? 62. Have you or has anyone close to you ever been the victim of a crime? [Yes/Unsure question privately] 63. Have you or has anyone close to you ever been the victim of a sexual crime? [Yes/Unsure question privately] 64. 'Juror's Background' The parties respectfully request that the Court ask each juror to state the following information: (a) the juror's age; (b) the juror's family status (including whether the juror has any children and, if so, ages of the children); (c) the juror's current town of residence and length of time at the residence; (d) the juror's county of residence during the past ten years; (e) the educational background (including the highest degree obtained); (f) the juror's occupation; (g) the name and general location of the juror's employer; and the period of employment (with that employer; (h) the same information concerning other employment within the last five years;",
      "position": "main body"
    },
    {
      "type": "handwritten",
      "content": "",
      "position": "none"
    },
    {
      "type": "printed",
      "content": "Commented [A1]: DEFENDANT. The defense intends to file a motion in limine rather than voir dire on these topics. See United States v. N.C. CaB. 238 (EDN.Y. 2018) (AMD); Elizabeth Holmes (Theranos), 18 F.4th 285, 286 (9th Cir. 2021) (NG); United States v. Robert Kelly, 19 F.4th 204 (2d Cir. 2021) (NG). Proposed Jury Questionnaire. In the most recent high-profile federal cases, the Government objects but it included the very same background information in the written questionnaire. In addition to saying to provide a good faith foundation for conducting research on the jurors to confirm or uncover bias, in longest financial fraud trials in SDNY was veritied in one of the juror due to false information on 'Juror T. F. 20-H-244 (SDNY (2012)).",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005372",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Elizabeth Holmes",
      "Robert Kelly"
    ],
    "organizations": [
      "SDNY"
    ],
    "locations": [
      "EDN.Y."
    ],
    "dates": [
      "10/22/21",
      "2012",
      "2018",
      "2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "367-1",
      "DOJ-OGR-00005372",
      "20-H-244"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with some margin notes. The document is page 15 of 17."
}