UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 22-CR-80173-CANNON-2

UNITED STATES OF AMERICA

-vsWILLIAM MICHAEL SPEARMAN

________________________________/

GOVERNMENT’S PROPOSED VOIR DIRE QUESTIONS 

FOR THE COURT TO CONSIDER ASKING THE VENIRE

1. Is there anyone here who does not use a computer (desktop or laptop) to 

connect to the Internet at home or at work?

2. Would any of you consider yourselves, and in what ways, to be computer 

experts (i.e. write or written code for computers, engaged in computer programming, 

conducted computer forensic examinations, have a degree in information technology, or 

built or repaired any type of computer hardware)?

3. Even though you may not have a background in computer science, systems 

administration, or forensic computer examination, how many of you have had some sort 

of formal computer training, and what kind?

4. Do you use Tor, the Tor Brower or ever access the “Dark Web” and if so, 

what for and what has been your experience?

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5. Do any of you belong to any group or subscribe to any publication which 

encourages, advocates or condones sexual relations between adults and children who are 

less than 18 years of age?

6. It is anticipated that the evidence in this case may consist of graphic 

descriptions of and discussions about sexually explicit conduct involving a minor child, 

including images depicting such conduct. Many people may find this material difficult 

to look at. Nevertheless, it is necessary for jurors to be exposed to some of this material 

during trial to ensure a fair and just outcome for the defendant and the government. 

Would being exposed to such material make you unable to perform your duties fairly 

and impartially as a juror in this case?

7. Some people are of the mistaken belief that possessing child pornography, 

including possessing child pornography by computer, is an activity that is protected by 

the Free Speech Clause of the First Amendment to our Constitution, or may otherwise be 

Constitutionally protected activity. I tell you that - as a matter of law - this is not the 

case – the First Amendment does not protect anyone from the prohibition against making, 

sending, receiving, accessing with intent to view, or possessing child pornography. 

Congress has passed laws which make the foregoing criminal offenses, and such activity 

is not protected by the First Amendment or by any other Constitutional right. Before I 

informed you just now that the possession or accessing with intent to view of child 

pornography was not conduct protected by the Constitution, did you believe that it was

or that it should be protected by any provision of the Constitution? 

a. Would you have any difficulty abiding by my instruction to you that 

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such activity is not - as a matter of law - protected by the First 

Amendment to the United States Constitution or by any other provision 

of the Constitution?

8. Will any of you have difficulty discussing sexual matters with other 

members of the jury - topics such as whether or not a particular image depicts sexually 

explicit conduct, as the judge will define those terms for you?

9. Have you, your spouse or any member of you family or close friends been 

the victim of sexual abuse, and if so was it reported to police, and did anything about that 

experience make you unable to be fair and impartial?

10. You will hear from witnesses in this case who are employed by the Federal 

Bureau of Investigation. Does anyone hold an unfavorable view of the Federal Bureau 

of Investigation and would the simple fact that a witness is employed by the Federal 

Bureau of Investigation, without more, make you less likely or more likely to believe their 

testimony?

MARKENZY LAPOINTE

UNITED STATES ATTORNEY

By: s/ Gregory Schiller ____________ 

GREGORY SCHILLER

Assistant United States Attorney

Court Id No. A5501906

U.S. Attorney’s Office - SDFL

500 S. Australian Ave., Suite 400

West Palm Beach, Florida 33401

Telephone: (561)209-1045

E-mail: gregory.schiller@usdoj.gov

Case 9:22-cr-80173-AMC Document 117 Entered on FLSD Docket 05/15/2023 Page 3 of 5
By: s/Kyle Reynolds

KYLE REYNOLDS

TRIAL ATTORNEY

U.S. Dept. of Justice, Criminal Division

Child Exploitation and Obscenity Section

Court ID # A5502872

1301 New York Avenue, NW

Washington, DC 20005

Phone: (202) 616-2842

Email: kyle.reynolds@usdoj.gov

By: s/William G. Clayman

WILLIAM G. CLAYMAN

TRIAL ATTORNEY

U.S. Dept. of Justice, Criminal Division

Child Exploitation and Obscenity Section

Court ID # A5502958

1301 New York Avenue, NW

Washington, DC 20005

Phone: (202) 514-0040

Email: william.clayman@usdoj.gov

Case 9:22-cr-80173-AMC Document 117 Entered on FLSD Docket 05/15/2023 Page 4 of 5
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on May 15, 2023, I electronically filed the foregoing 

document with the Clerk of the Court using CM/ECF 

s/William G. Clayman

William G. Clayman

Trial Attorney, U.S. Dept. of Justice

Case 9:22-cr-80173-AMC Document 117 Entered on FLSD Docket 05/15/2023 Page 5 of 5