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Case 1:20-cr-00330-PAE Document 342 Filed 10/13/21 Page10of17 answers that seem acceptable to the Court and counsel. For example, in this case it is necessary to ask jurors if they or a family member have ever been a victim of sexual abuse—a question that most jurors will not be inclined to answer in public. In a case that has received media attention or involves a well-known defendant, a larger jury panel is often assembled in an attempt to increase the odds of obtaining a fair jury. The paradox is that a larger panel can mean that jurors are even less inclined to speak up in front of a large group. Accordingly, in a high-publicity case such as this, q questionnaire alone is insufficient. B. Individual Sequestered Voir Dire is Necessary Due to the Sensitive Nature of the Charges The nature of the charges in this case poses special problems for jury selection rarely encountered in the average federal jury trial. The crimes charged (concerning sexual abuse of minors) are particularly inflammatory and of great concern to communities from which jurors are drawn. The charges tap into strongly held moral, ethical, and religious beliefs concerning appropriate, inappropriate, and immoral behavior and conduct, and can produce visceral and emotional reactions leading to more severe judgments based on preconceived viewpoints rather than on admissible evidence presented at trial As such, prospective jurors’ opinion and beliefs regarding the nature of the crimes charged will need to be addressed through procedures that maximize juror openness, honesty, and candor. It is only through in-depth questioning and exploration of jurors’ views on these issues that both the defense and prosecution can uncover what is needed to pursue challenges for cause and to intelligently exercise peremptory challenges. The experiences and backgrounds of jurors could have significant bearing on the potential biases that they have. A variety of potential experiences, both general (e.g., being a victim of a crime or closely related to a victim) and specific (e.g., harassment, molestation, unwanted sexual contact, sexual assault, rape, domestic DOJ-OGR-00005215