IN THE DISTRICT COURT OF THE UNITED STATES

FOR THE MIDDLE DISTRICT OF ALABAMA

NORTHERN DIVISION

)

UNITED STATES OF AMERICA )

 )

 v. ) CR. NO. 2:06-CR-202-WKW

 )

EUGENE L. CLECKLER and )

KIM CLECKLER )

)

United States’s Requested Voir Dire Questions

In addition to the standard questions that the Court asks of the jury venire in this

District, the United States also requests that the Court ask the attached additional

questions. The United States respectfully reserves the right to submit additional requests

as developments in this case may warrant. 

Respectfully submitted this 28th day of December, 2006,

LEURA G. CANARY

United States Attorney

/s/ Christopher A. Snyder 

ANDREW O. SCHIFF CHRISTOPHER A. SNYDER

Deputy Chief, Criminal Division Assistant United State Attorney

One Court Square, Suite 201 One Court Square, Suite 201

Montgomery, AL 36104 Montgomery, AL 36104

Phone: (334) 223-7280 Phone: (334) 223-7280

Fax: (334) 223-7135 Fax: (334) 223-7135

E-mail: andrew.schiff@usdoj.gov E-mail: christopher.a.snyder@usdoj.gov 

Case 2:06-cr-00202-WKW-CSC Document 66 Filed 12/28/2006 Page 1 of 5
I. Prior Experience with Law Enforcement or Government

1. Has a relative or close friend of any panel member ever been employed by a

local, state, or federal law enforcement agency? What about employment with a local,

state, or federal government? 

If so, what position was or is held? 

2. Has any member of the panel ever had any training in law or in law

enforcement?

If so, please describe.

3. Other than a traffic ticket, has any member of the panel ever had an unpleasant

experience involving law enforcement?

If so, please explain.

II. Collection of Income Taxes and the Internal Revenue Service

4. Does anyone believe that the Federal Government does not have the right to

collect individual income taxes? 

5. Do any of you have any reason why you would be unable to give either the

government or the defendant a fair trial based solely upon the fact that the IRS is

involved?

6. Has any member of the jury panel, or any member of your family ever been

audited by the IRS, or a state or local tax agency?

If so, please elaborate.

Case 2:06-cr-00202-WKW-CSC Document 66 Filed 12/28/2006 Page 2 of 5
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7. Other than an audit, have you or any of your friends or relatives ever had any

unfavorable association or dealings with the IRS or a state or local tax agency? 

If so, please elaborate? 

8. Has any member of the panel ever had any dealings with the Internal Revenue

Service’s Criminal Investigation Unit? 

If so, please elaborate.

III. Moral, Religious, or Ethical Concerns

9. Do any of you have any feelings, whether they may be moral, religious,

philosophical or otherwise, that would prevent you from being a fair and impartial juror

in this case or that would prevent you from sitting in judgment on your fellow man? 

10. To admit to having some sympathy for the defendant or the government in this

case is nothing to be ashamed of and does not reflect badly upon you as a person. 

However, both the government and the defendant are entitled to have this case heard by a

fair and impartial jury that will decide the case solely according to the evidence admitted

in this Court and according to the Court's instructions on the law. The law provides that

the jury may not be governed by sympathy, prejudice, or public opinion. With this in

mind, do any of you have any reason why you would be unable to give either the

government or the defendant a fair trial based solely upon the evidence admitted at the

trial and the instructions given by the Court?

Case 2:06-cr-00202-WKW-CSC Document 66 Filed 12/28/2006 Page 3 of 5
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IV. Instructions from the Court; Sentencing

11. Can all of you decide this case solely on the evidence presented in this

courtroom, applying the law as given to you by the Court, and decide it without bias,

prejudice, and sympathy? If not, please elaborate.

12. Is there any reason why any of you would be unable to reach a fair and

impartial verdict based solely upon the evidence submitted during the trial and the

instructions which the judge gives you?

13. Do all of you realize that as a juror, in your deliberations as to guilt, you must

not consider any possible punishment?

Case 2:06-cr-00202-WKW-CSC Document 66 Filed 12/28/2006 Page 4 of 5
IN THE DISTRICT COURT OF THE UNITED STATES

FOR THE MIDDLE DISTRICT OF ALABAMA

NORTHERN DIVISION

)

UNITED STATES OF AMERICA )

 )

 v. ) CR. NO. 2:06-CR-202-WKW

 )

EUGENE L. CLECKLER and )

KIM CLECKLER )

)

Certificate of Service

I hereby certify that on December 28, 2006, I electronically filed the foregoing with

the Clerk of Court, using the CM/ECF system, which will send notification of such filing to

to all attorneys of record. 

LEURA G. CANARY

United States Attorney

/s/ Christopher A. Snyder 

ANDREW O. SCHIFF CHRISTOPHER A. SNYDER

Deputy Chief, Criminal Division Assistant United State Attorney

One Court Square, Suite 201 One Court Square, Suite 201

Montgomery, AL 36104 Montgomery, AL 36104

Phone: (334) 223-7280 Phone: (334) 223-7280

Fax: (334) 223-7135 Fax: (334) 223-7135

E-mail: andrew.schiff@usdoj.gov E-mail: christopher.a.snyder@usdoj.gov 

Case 2:06-cr-00202-WKW-CSC Document 66 Filed 12/28/2006 Page 5 of 5