{
  "document_metadata": {
    "page_number": "13",
    "document_number": "367",
    "date": "10/22/21",
    "document_type": "Juror Questionnaire",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 13 of 35 Juror ID: Have you ever filed a criminal complaint? Yes No If Yes, please explain: Have you ever contacted any prosecutor office: State District Attorney, United States Attorney's Office, State Attorney General? Yes No If Yes, please explain the reason: Have you ever reported someone for wrongdoing to your employer or a government agency? Yes No If Yes, please explain: Other than for a minor traffic citation, have you ever been arrested for, charged with, or convicted of a crime? Yes No If Yes, please explain: MEDIA ISSUES How much do you rely on the following sources for your news? A lot Somewhat Not much Not at all Newspapers: Social Media: Television: Radio: Internet: Conversations: Other: How often do you use or access those sources: Daily Occasionally Rarely -13- Commented [A18]: GOVERNMENT OBJECTION: The Government objects to the 'Media Issues' section proposed by the defense as unnecessary and more prejudicial than probative under the Court's Order. The Government submits that its proposed questions ask the jurors what is necessary on the subject but is not as unduly burdensome as the defendant's proposal. Many of the questions are vague, confusing, and argumentative. Commented [A19R18]: DEFENDANT RESPONSE: A critical purpose of individual voir dire is to ascertain what content the jurors have read and what they think they know about the case. The First Circuit's well-reasoned opinion in In re Tsarnaev, currently pending before the First Circuit, explains why. It is insufficient simply to ask the jurors if they think they can be fair even after seeing media about the case. See, e.g., United States v. Tsarnaev, 968 F.3d 24, (1st Cir. 2020) (failure to ask juror to identify what content they had already read about the case and to identify what they already thought they knew about the grounds for reversal of death sentence), cert. granted, 141 S.Ct. 1683 (Mar. 22, 2021), oral argument scheduled (Oct. 13, 2021); Patriarca v. United States, 402 F.2d 314, 318 (1st Cir. 1968) (judge must elicit 'the kind and degree' of each prospective juror's exposure to the case or the parties 'if asked by counsel'); Smith v. Phillips, 455 U.S. 209, 221-22 (1982) (O'Connor, concurring) ('prospective juror 'may have been tainted in concealing their own bias' or 'may be unaware of it'). Further, as in Tsarnaev, decision, much of the information shown on the media about Ms. Maxwell and Mr. Epstein is either inaccurate or inadmissible, or pertains to persons and charges not before this jury. See, e.g., United States v. Epstein, No. 18-cr-582 (JPO) (ECF No. 267) (granting in part motion to preclude 'largely factual accounts, some of the coverage included inaccurate or inadmissible information — like the details of his un-Mirandized hospital interview and the opinions of public officials that he should die') (citation omitted). It also included a number of individuals' personal opinions regarding Ms. Maxwell's guilt. DOJ-OGR-00005335",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 13 of 35",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Juror ID:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Have you ever filed a criminal complaint? Yes No If Yes, please explain:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Have you ever contacted any prosecutor office: State District Attorney, United States Attorney's Office, State Attorney General? Yes No If Yes, please explain the reason:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Have you ever reported someone for wrongdoing to your employer or a government agency? Yes No If Yes, please explain:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Other than for a minor traffic citation, have you ever been arrested for, charged with, or convicted of a crime? Yes No If Yes, please explain:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "MEDIA ISSUES",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "How much do you rely on the following sources for your news? A lot Somewhat Not much Not at all Newspapers: Social Media: Television: Radio: Internet: Conversations: Other:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "How often do you use or access those sources: Daily Occasionally Rarely",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "-13-",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "Commented [A18]: GOVERNMENT OBJECTION: The Government objects to the 'Media Issues' section proposed by the defense as unnecessary and more prejudicial than probative under the Court's Order. The Government submits that its proposed questions ask the jurors what is necessary on the subject but is not as unduly burdensome as the defendant's proposal. Many of the questions are vague, confusing, and argumentative.",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "Commented [A19R18]: DEFENDANT RESPONSE: A critical purpose of individual voir dire is to ascertain what content the jurors have read and what they think they know about the case. The First Circuit's well-reasoned opinion in In re Tsarnaev, currently pending before the First Circuit, explains why. It is insufficient simply to ask the jurors if they think they can be fair even after seeing media about the case. See, e.g., United States v. Tsarnaev, 968 F.3d 24, (1st Cir. 2020) (failure to ask juror to identify what content they had already read about the case and to identify what they already thought they knew about the grounds for reversal of death sentence), cert. granted, 141 S.Ct. 1683 (Mar. 22, 2021), oral argument scheduled (Oct. 13, 2021); Patriarca v. United States, 402 F.2d 314, 318 (1st Cir. 1968) (judge must elicit 'the kind and degree' of each prospective juror's exposure to the case or the parties 'if asked by counsel'); Smith v. Phillips, 455 U.S. 209, 221-22 (1982) (O'Connor, concurring) ('prospective juror 'may have been tainted in concealing their own bias' or 'may be unaware of it'). Further, as in Tsarnaev, decision, much of the information shown on the media about Ms. Maxwell and Mr. Epstein is either inaccurate or inadmissible, or pertains to persons and charges not before this jury. See, e.g., United States v. Epstein, No. 18-cr-582 (JPO) (ECF No. 267) (granting in part motion to preclude 'largely factual accounts, some of the coverage included inaccurate or inadmissible information — like the details of his un-Mirandized hospital interview and the opinions of public officials that he should die') (citation omitted). It also included a number of individuals' personal opinions regarding Ms. Maxwell's guilt.",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005335",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "O'Connor",
      "Maxwell",
      "Epstein",
      "Tsarnaev"
    ],
    "organizations": [
      "United States Attorney's Office",
      "State Attorney General",
      "First Circuit",
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "10/22/21",
      "Mar. 22, 2021",
      "Oct. 13, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 367",
      "18-cr-582"
    ]
  },
  "additional_notes": "The document appears to be a juror questionnaire from a court case. The document contains a mix of printed and blank spaces for handwritten responses. There are also comments and objections from the government and defendant's response in the margin."
}