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Case 1:20-cr-00330-PAE Document367 Filed 10/22/21 Juror ID: CHARGES AND INDIVIDUALS INVOLVED The indictment alleges that Ghislaine Maxwell conspired with Jeffrey Epstein and did entice minor females to travel to engage in illegal sex acts, transported a minor female to engage in criminal sexual activity, and engaged in sex trafficking of a minor. The indictment is not evidence; it is a formal way of charging a person with a crime in order to bring her to trial. Ms. Maxwell has pleaded not guilty. She is presumed innocent. Unless the government proves that she is guilty of these charges beyond a reasonable doubt, the jury must return a verdict of not guilty. Would the fact that Ms. Maxwell faces a number of charges lead you to believe that she must be guilty of something? Yes No If yes, please explain: Please indicate if you ever had any connection with any of the following? Palm Beach County (Florida) Police Department Yes No Federal Bureau of Investigations Yes No U.S. Attorney’s Office -Southern District of Floridal Yes No U.S. Attorney’s Office- Southern District of New York Yes No U.S. Department of Justice Yes No Page 11 of 35 Commented [A13]: GOVERNMENT OBJECTION: The Government objects to the “Charges & Individuals Involved” section proposed by the defendant on the grounds that it is duplicative of the questions proposed by the Government. In particular, the first question is duplicative of questions above and is argumentative and inappropriate. Commented [A14R13]: DEFENDANT RESPONSE: The Government has not identified which questions they believe are uplicative. The first question, pertaining to the number of charges, loes not appear to be duplicated in any Government-proposed. question. The Second Circuit has specifically approved discussion pf the presumption of innocence in jury selection. See United States v. Velez-Vasquez, 116 F.3d 58, 61 (2d Cir. 1997) (upholding conviction where judge forgot to instruct on presumption of innocence in closing instructions where the concept had been iscussed during voir dire). Commented [A15]: GOVERNMENT OBJECTION: The Government objects to any references to the Southern District of Florida at this trial. The U.S. Attomey’s Office for the Southem District of Florida is not prosecuting this case. As the Government will address in a motion in limine, references to the USAO-SDFL are not appropriate at this trial. If you indicated Yes, please explain your connection: Commented [A16]: GOVERNMENT OBJECTION: The Government does not believe the questions in the “Experience with Legal System’ section should be included in the written questionnaire, because these questions will not reveal any bias or otherwise provide a basis for a for-cause challenge. Rather, the Government submits that such questions should be asked during the oral voir dire. EXPERIENCE WITH LEGAL SYSTEM Commented [A17R16]: DEFENDANT RESPONSE: The defense believes that asking these questions on the questionnaire No Have you ever served as a juror at trial or in a grand jury? DO Yes If yes, how many times? will save substantial amount of time and will allow the Court (and potentially parties) to follow up at the time of voir dire. Access to the information ahead of the voir dire will allow the Court to prepare to ask individual questions as necessary, some of which may best be asked outside the presence of other jurors (for example a prospective -11- juror who previously had a negative experience as a juror). DOJ-OGR-00005333