{
  "document_metadata": {
    "page_number": "12",
    "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 12 of 17\nevidence obtained from those searches is admissible in this case. Do you have any feelings or opinions 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?\n43. You also may hear testimony in this case from expert witnesses. Have any of you had any experiences with experts, or do you have any general feelings about the use of experts that would affect your ability to be fair and impartial in this case?\n44. Does anyone have any expectations about the types of evidence that the Government should or will present in this criminal trial, or in a criminal trial more generally?\n45. Is there anything that has been covered or that has not been covered that you wish to discuss privately with the Court and counsel?\n46. Would any of you be unable to follow my instructions that the Government is not required to use any particular investigative technique uncovering evidence of or prosecuting crime?\n47. The defendant is charged with acting with others in the commission of the charged crimes. Those other individuals are not on trial here. You may not draw any inference, favorable or unfavorable, toward the government or the defendant from that fact. You also may not speculate as to the reason why other persons are not on trial. Is there anyone who cannot follow this instruction or for this reason could have difficulty rendering a fair and impartial verdict?\nFunction of the Court and Jury\n48. The function of the jury is to decide questions of fact. You are the sole judges of the facts and nothing that the Court or the lawyers say or may encroach in any way on your role as fact finders. You must take your instructions as to the law from the Court and you are bound by those instructions. However, when it comes to the law, you may not substitute your notions of the case or your views of the law for the instructions given to you by the Court.\nCommented [1A13]: DEFENDANT OBJECTION: This question mirrors a standard jury instruction on this subject.\nCommented [1A14]: DEFENDANT OBJECTION: The Sixth Amendment secures the right to trial by jury. U.S. Const. amend. VI; United States v. Gaudin, 515 U.S. 506 (1995). The function of the jury is to decide questions of fact. United States v. Williams, 461 U.S. 648 (1983); see also 3B1 S. Childress & M. Davis, Federal Standards of Review § 14.03 (4th ed. 2010). The Government proposed questions are not designed to be an opportunity for one party to inject their theory of the case or prejudice the other. For example, there are grounds to object to a particular evidence for the jury (such as missing the law). The Government's question also misstates the law. For example, there are witness instructions that would allow the jury to draw inferences against the Government based on the absence of certain testifying individuals.\nDOJ-OGR-00005369",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 367-1 Filed 10/22/21 Page 12 of 17",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "evidence obtained from those searches is admissible in this case. Do you have any feelings or opinions 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?",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "43. You also may hear testimony in this case from expert witnesses. Have any of you had any experiences with experts, or do you have any general feelings about the use of experts that would affect your ability to be fair and impartial in this case?",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "44. Does anyone have any expectations about the types of evidence that the Government should or will present in this criminal trial, or in a criminal trial more generally?",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "45. Is there anything that has been covered or that has not been covered that you wish to discuss privately with the Court and counsel?",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "46. Would any of you be unable to follow my instructions that the Government is not required to use any particular investigative technique uncovering evidence of or prosecuting crime?",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "47. The defendant is charged with acting with others in the commission of the charged crimes. Those other individuals are not on trial here. You may not draw any inference, favorable or unfavorable, toward the government or the defendant from that fact. You also may not speculate as to the reason why other persons are not on trial. Is there anyone who cannot follow this instruction or for this reason could have difficulty rendering a fair and impartial verdict?",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "Function of the Court and Jury",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "48. The function of the jury is to decide questions of fact. You are the sole judges of the facts and nothing that the Court or the lawyers say or may encroach in any way on your role as fact finders. You must take your instructions as to the law from the Court and you are bound by those instructions. However, when it comes to the law, you may not substitute your notions of the case or your views of the law for the instructions given to you by the Court.",
      "position": "main"
    },
    {
      "type": "handwritten",
      "content": "Commented [1A13]: DEFENDANT OBJECTION: This question mirrors a standard jury instruction on this subject.",
      "position": "margin"
    },
    {
      "type": "handwritten",
      "content": "Commented [1A14]: DEFENDANT OBJECTION: The Sixth Amendment secures the right to trial by jury. U.S. Const. amend. VI; United States v. Gaudin, 515 U.S. 506 (1995). The function of the jury is to decide questions of fact. United States v. Williams, 461 U.S. 648 (1983); see also 3B1 S. Childress & M. Davis, Federal Standards of Review § 14.03 (4th ed. 2010). The Government proposed questions are not designed to be an opportunity for one party to inject their theory of the case or prejudice the other. For example, there are grounds to object to a particular evidence for the jury (such as missing the law). The Government's question also misstates the law. For example, there are witness instructions that would allow the jury to draw inferences against the Government based on the absence of certain testifying individuals.",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005369",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "U.S. Const.",
      "United States"
    ],
    "locations": [],
    "dates": [
      "10/22/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "367-1",
      "DOJ-OGR-00005369"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal trial. The text includes jury instructions and objections from the defendant. The document is well-formatted and legible."
}