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United States v. Al-Timimi:

Jury Questionnaire

Hon. Leonie M. Brinkema

Eastern District of Virginia

March 28, 2005

The following questionnaire was prepared by the Eastern District of Virginia s

United States District Judge Leonie M. Brinkema to to facilitate jury selection in

a prosecution for terrorism, United States v. Al-Timimi, No. 1:04-cr-385 (E.D. Va. Sept. 23, 2004).

Jury Questionnaire

Questions Juror No. 

1. Name: 

2. Indicate the city or county of your current residence.

City: County: 

3. Length of time at current address: 

4. Are you: Male Female 

5. How old are you? 

6. In what country were you born? 

7. How long have you lived in Northern Virginia? 

8. Is English your first language? Yes No 

9. If English is not your first language, do you have any difficulty reading, writing, speaking, or understanding English?

Yes No 

10. Please indicate your present marital status.

Married

Single (never married)

Widowed

Separated or Divorced
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11. Are you, your spouse, or former spouse a naturalized U.S. citizen? For this

and all of the following questions, the definition of spouse includes the

husband or wife of a married individual and the significant other or domestic 

partner of an unmarried individual.

Yes No 

12. Are you employed? Yes No 

(a) If employed, what is your current occupation/job title? 

(b) How long have you held this job? 

(c) Name of employer: 

13. If you are unemployed, are you:

a student between jobs disabled

a homemaker retired

(a) If you are a student, where do you attend school? 

(b) If retired or between jobs, what type of work had you been doing? 

Do you have a second job? Yes No 

If yes, what do you do? 

15. Is your spouse employed outside the home?

Yes No Do not have a spouse 

(a) If employed, what is his or her current occupation/job title?

(b) How long has he or she held this job? 

16. Check the highest level of education for you and your spouse.

You Spouse 

Grade school or less ______ ______ Some high school ______ ______ High school graduate ______ ______ Technical or business school ______ ______ Some college ______ ______ College degree ______ ______ Graduate degree (and describe area) ______ ______ Area: 
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17. Do you or your spouse have any education, training, work experience, or

special expertise in (check all that apply):

You Spouse 

(a) Aerospace technology (NASA or related programs) ______

(b) Criminal justice, law enforcement ______

(c) Firearms, explosives ______

(d) History, political science ______

(e) Journalism, media ______

(f) Law ______

(g) Military, military history ______

(h) Religion or philosophy ______

If yes, please list and describe the training, experiences, or expertise. 

18. Do you speak Arabic or Urdu (or any dialect of Arabic or Urdu), or did you

grow up in households where the Arabic or Urdu language or any of their dialects were spoken?

Yes No 

(a) If you speak, read, or understand the Arabic or Urdu languages (or any of 

their dialects), would you have any difficulty relying solely upon the

official interpreter s translation of testimony and witnesses translations

of Arabic or Urdu language evidence?

Yes No 

(b) Do you read any Arabic or Urdu language newspapers or publications?

Yes No 

If so, please list the Arabic or Urdu language newspapers or publications. 

19. Do you watch any Arabic language television programs, including newscasts?

Yes No 

If yes, please list these programs/newscasts. 

20. The defendant in this case is of Arabic or Middle Eastern descent. Are you, your spouse, or any of your immediate family or close personal friends of

Arabic or Middle Eastern descent?

Yes No 
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21. Do you have an opinion regarding establishing Shariah (Islamic law) in the

United States?

Yes No 

If yes, please explain. 

22. Have you, your spouse, or any immediate family member or close personal 

friend had any contact or dealings with Dar al Arqam Islamic Center, also

known as the Center for Islamic Information and Education, located in Falls

Church, Virginia?

Yes No 

If yes, please explain. 

23. Is there anything about a case in which a defendant or witnesses are Muslim 

(which means they practice Islam) that would make it hard for you to serve

as a fair and impartial juror?

Yes No 

If yes, please explain. 

24. Do you know anyone who is currently, or was within the past four years, either an employee of or a student in the philosophy or computational biology 

departments at George Mason University or an employee of SRA International?

Yes No 

If yes, please explain. 

25. Do you have regular access to the Internet? Yes No 

If yes, how often do you access the Internet? 
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26. Have you, your spouse, or any member of your immediate family ever served 

in the armed forces?

Yes No 

(a) If yes, please answer the following:

You Spouse Family Member

Branch and highest rank 

Dates of service 

Type of discharge 

(b) Were you, your spouse, or any member of your immediate family ever

involved in a court martial? Yes No 

If yes, please explain. 

27. If you or any member of your immediate family served in the military, were

you or they ever in a combat situation?

Yes No 

If yes, please state where and when. 

28. Have you, your spouse, or any immediate family member or close personal 

friend lived, worked, or traveled in any of the following countries, or are they 

currently living, working, or traveling there: Saudi Arabia, Bosnia, Afghanistan, Iraq, Iran, Pakistan, India, Chechnya, Israel, Palestine, or Kashmir?

Yes No 

If yes, please explain where and when. 

29. Have you, your spouse, or any immediate family member or close personal 

friend been injured or killed while serving in a combat or a military zone in

Iraq, Afghanistan, or elsewhere in the Middle East?

Yes No 

If yes, please explain. 
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30. Do you, your spouse, or any immediate family member or close personal 

friend know anyone who was a victim or the immediate family member of a

victim of a terrorist attack that occurred in the United States or anywhere 

abroad?

Yes No 

If yes, please explain. 

31. Have you, your spouse, or any immediate family member or close personal 

friend altered any travel plans as a result of the events of September 11, 2001?

Yes No 

If yes, please explain. 

32. Did you, your spouse, or any immediate family member or close personal 

friend assist or participate in any way in rescue or relief efforts, or advocacy 

efforts for victims, after any terrorist attack occurring in the United States, including the September 11, 2001, attacks on the Pentagon and the World

Trade Center in New York, or anywhere else abroad?

Yes No 

If yes, please explain. 

33. Have you, your spouse, or any immediate family member or close personal 

friend been to Ground Zero, the site of the World Trade Center, since September 11, 2001, or participated in any ceremony or special event honoring 

any of the victims of the September 11, 2001, attacks?

Yes No 

If yes, please explain. 
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34. Have you, your spouse, or any immediate family member or close personal 

friend applied for employment with, been employed by, or volunteered with

any of the following organizations or agencies? (Check all that apply.)

Family/

You Spouse Friend

(a) Any law enforcement agency 

(such as a police department; 

sheriff s office; FBI; DEA;

ATF; U.S. Marshal s Service;

U.S. Park Police; Justice 

Department; a District, 

Commonwealth or State s

Attorney s Office; a parole

office; a probation office; 

Bureau of Prisons; military 

police; private security police)? _____ ______

(b) Any local, state, or national 

security or self defense agency 

(including the Department of 

Homeland Security)? _____ ______

(c) Any military or civilian 

intelligence agency (such as 

CIA)? _____ ______

(d) Office of any member of the 

U.S. Congress (U.S. Senate or 

House of Representatives, 

including Congressional 

subcommittee experience)? _____ ______

(e) The White House or the Office 

of the President? _____ ______

If yes, please explain. 

35. Do you, your spouse, or any immediate family member or close personal 

friend own or have experience with firearms or participate in any activity using firearms?

Yes No 

If yes, what type and for what purpose? 
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36. Do you or any member of your immediate family or a close personal friend

participate in or have any experience with paint ball?

Yes No 

If yes, please describe. 

37. Have you read or heard any news coverage or received information from any

other source regarding a Virginia jihad ?

Yes No 

If yes, please describe what you have read or heard and from what source. 

38. Have you read or heard any news coverage or received information from any

other source about a criminal case in Northern Virginia described as the

Virginia paint ball case?

Yes No 

If yes, please describe what you have read or heard and from what source. 

39. Do you know anyone who was a defendant, witness, lawyer, investigator, or

otherwise involved or associated in any way with a criminal case in Northern 

Virginia described as the the Virginia Jihad case or the Virginia paint 

ball case?

Yes No 

If yes, please explain. 

40. What is your reaction or opinion toward persons living in the United States

who choose to associate with groups or organizations, including religious

groups and organizations, that discuss or advocate the use of violence as a

means to protest or to express their opposition to the United States government s policies?
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41. Is there anything in particular about a case involving charges related to potential acts of terrorism that would make it difficult for you to serve as a fair

and impartial juror in such a case?

Yes No 

If yes, please explain. 

42. The Government is represented in this case by the United States Attorney, 

Paul J. McNulty, though the conduct of the case is in the immediate charge 

of the Government attorneys appearing in the courtroom. To your knowledge, do you, your spouse, or any immediate family member or close personal friend know or have any connection with Paul J. McNulty or with any

of the following persons who will be seated at the counsel table for the government?

Paul J. McNulty, United States Attorney Yes No 

Gordon D. Kromberg, Assistant United States 

Attorney Yes No 

John T. Gibbs, Trial Attorney, U.S. Department of 

Justice Yes No 

John Wyman, Special Agent, Federal Bureau 

of Investigation Yes No 

Wade Ammerman, Special Agent, Federal

Bureau of Investigation Yes No 

(a) If yes, please explain. 

(b) Have you seen, heard, or read anything about any of these individuals? 

This includes not only through the media, but anything you may have

heard from friends, relatives, or co-workers.

Yes No 

If yes, please describe what you have seen, read, or heard and from what

source. 
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43. Do you, your spouse, or any immediate family member or close personal 

friend know or have any connection with the defendant, Dr. Ali al-Timimi, or 

any member of his family, including his father Mr. Mehdi al-Timimi, a retired diplomat from Iraq, who also served as a consultant to embassies and

law firms, and his mother Dr. Sahera al-Timimi, who is employed by the

District of Columbia Department of Mental Health and teaches at the University of the District of Columbia?

Yes No 

If yes, what connection do you/they have with Dr. al-Timimi or his family? 

44. Dr. al-Timimi, is a U.S. citizen, a resident of northern Virginia, and was a

Ph.D. candidate at George Mason University during the course of the criminal investigation preceding his indictment on these charges. Dr. al-Timimi is

an Islamic scholar and was a lecturer at Dar al Arqam Islamic Center, also

known as the Center for Islamic Education and Information located in Falls

Church, Virginia. Have you seen, heard, or read anything about the defendant? This includes not only through the media, but anything you may have 

heard from friends, relatives, or co-workers.

(a) If yes, please describe what you have seen, read, or heard and from what

source. 

(b) If yes, has this left you with any impression about the innocence or guilt

of Dr. al-Timimi?

Yes No 

If yes, please explain. 
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45. The defendant, Dr. al-Timimi, is represented by two lawyers: Edward B. MacMahon, Jr., whose office is in Middleburg, VA, and Alan H. Yamamoto, 

whose office is in Alexandria, VA.

(a) To your knowledge, do you, your spouse, or any immediate family 

member or close personal friend know or have any connection with either lawyer or his staff?

Edward B. MacMahon, Jr. Yes No 

Alan H. Yamamoto Yes No 

(b) If you answered yes for either individual, describe the connection. (c) Have you seen, heard, or read anything about either of these attorneys or

his staff? This includes not only through the media, but anything you

may have heard from friends, relatives, or co-workers.

Yes No 

(d) If yes, please describe what you have seen, read, or heard and from what

source. 

46. Do you, your spouse, or any immediate family member or close personal 

friend have any connection with, or have you ever seen, heard, or read anything about, any of the individuals listed below who may be a witness or who 

may be mentioned at trial?

Mohammed Aatique Ibrahim al-Hamdi Yong Kwon

Robert Andrews Haytham Hantash Mamdouh Mohamed

Sabri Benkhala Khwaja Hasan Randall Ismail Royer

Soliman al-Buthi Sefer Hawali Caliph Ibn Abdur-Raheem

Charles Butterworth Jafaar Idris Hammad Abdur-Raheem

Ali Asad Chandia Masaud Khan Donald Surratt

Seifullah Chapman Evan Kohlmann Rashid Thompson

Nabil Gharbieh

Yes No 

(a) If yes, please list the individual s name and explain the connection or

what you have seen, read, or heard and from what source. 
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47. The judge who will preside over this case is The Honorable Leonie M. Brinkema of the United States District Court for the Eastern District of Virginia. 

Do you, your spouse, or any immediate family member or close personal 

friend know or have any connection with Judge Brinkema or any of her staff?

Yes No 

48. Have you seen, heard, or read anything about this case?

Yes No 

(a) If yes, please explain what you have seen, heard, or read and from what

source. 

49. Is there anything you have seen, heard, or read about this case that would

interfere with your ability to render a fair verdict in this case based solely on

the evidence presented in court?

Yes No 

(a) If yes, please explain what you have seen, heard, or read and from what

source. 

50. Have you formed an opinion as to the innocence or guilt of the defendant, 

Dr. Ali al-Timimi, in this case?

Yes, I have formed an opinion 

No, I have not formed an opinion 

51. This case is likely to receive ongoing media attention. The Court wants to

make sure that this case is decided solely on the evidence in the courtroom

and not based on things that are said outside the courtroom. Accordingly, the

Court will require that you avoid reading about the case in the newspapers or

listening to any radio or television reports about the case. The Court will also 

require that you avoid discussing this case with friends or family during the

course of the trial. You will also be required not to use the Internet or any

other tool to research any issue raised in this case while you are a juror. Would these requirements pose any difficulty for you?

Yes No 
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52. Are you, your spouse, or any immediate family member or close personal 

friend a member of a neighborhood crime watch or prevention group?

Yes No 

If yes, please identify the group and describe that participation. 

53. Are you, or have you ever been, a member of any victim s rights group?

Yes No 

If yes, please identify the group and describe your participation. 

54. Have you, your spouse, or any immediate family member or close personal 

friend ever been charged with a crime or been the subject of a criminal investigation?

Yes No 

If yes, please explain. 

55. Have you ever appeared or testified as a witness in any investigation or legal

proceeding?

Yes No 

If yes, please explain. 

56. Are you, your spouse, or any immediate family member or close personal 

friend now under subpoena or, to your knowledge, about to be subpoenaed in 

a criminal case?

Yes No 

If yes, please explain. 
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57. Have you ever been questioned in any matter by the state or local police, any

state or local law enforcement agency, or by the Department of Justice or any 

United States investigative agency such as the Federal Bureau of Investigation (FBI), Drug Enforcement Administration (DEA), Department of Homeland Security, Internal Revenue Service (IRS), or the Bureau of Immigration 

and Customs Enforcement (BICE)?

Yes No 

If yes, please explain. 

58. (a) Have you ever:

(1) Served as a juror in a civil case? Yes No 

(2) Served on a grand jury? Yes No 

(3) Served as a juror in a criminal case? Yes No 

(4) Been a juror in a case where the jury

was unable to reach a verdict? Yes No 

(b) If you have served on a jury, please list below (1) the approximate year;

(2) whether you served in state court or federal court; (3) whether it was

a grand jury or a trial jury; (4) what the general nature of the case was

(for example, robbery, murder, contract, negligence, medical malpractice, etc.); (5) whether or not a verdict was reached; and (6) if there was a 

verdict, what it was.

(1) Year

(2) State or 

Federal 

Jury

(3) Grand 

Jury or 

Trial Jury

(4) Nature 

of Case

(5) Was 

There a 

Verdict?

(6) What 

Was the 

Verdict?

If you need additional space to complete this or any other answer, please

write continued, go to the blank pages at the back of the questionnaire, indicate the number of the question, and continue your answer.
United States v. Al-Timimi: Jury Questionnaire

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59. Do you personally, or in connection with your business, have any pending 

interest in any legal action or dispute with the United States, or any officer, agent, or employee of the United States?

Yes No 

If yes, please explain the nature of your interest in such proceedings. 

60. You may hear testimony in this case concerning the use of accomplices or

informants by federal authorities in their investigations or through undercover operations. One or more of those individuals may be called to testify in

this case, and you may learn that some of these individuals have participated 

in serious crimes. An accomplice or an informant is a competent witness and

a recognized means of law enforcement. You will determine the credibility

of these individuals and how much weight to give their testimony. Do you

have strongly held feelings against the use of accomplices or informants?

Yes No 

61. Have you, your spouse, or any immediate family member or close personal 

friend ever been the victim of a serious crime?

Yes No 

If yes, please describe. 

62. Have you ever had a particularly favorable or unfavorable experience with a

lawyer or judge? (So memorable that it still stands out in your mind.)

Yes No 

If yes, please explain. 

63. Have you, your spouse, or any immediate family member or close personal 

friend had a particularly favorable or unfavorable experience with law enforcement personnel or an investigating agent? (So memorable that it still

stands out in your mind.)

Yes No 

If yes, please explain. 
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64. There may be evidence in this case consisting of tape recordings of conversations taking place over the telephone through the use of electronic devices 

commonly known as wiretaps. There may also be evidence obtained by

audio tapes which were made by a witness through what is known as a consensual tape recording. A consensual tape recording is a recording in which

only one party to the conversation consents to the conversation being tape

recorded and the other party did not know the conversation was being taped. The Court will have ruled on whether this wiretap or tape recording is lawfully before you. Consensual tape recordings may occur over the telephone

or in face-to-face conversations. Do you have strongly held views regarding

the use of such evidence at trial?

Yes No 

If yes, please explain. 

65. There may also be evidence obtained from photographic and physical surveillance as well as evidence seized pursuant to lawful searches of various

places, including the homes of the defendant and others. Do you have any

feelings regarding the use of lawfully conducted surveillance or searches?

Yes No 

If yes, please explain. 

66. To your knowledge, have you, your spouse, or any immediate family member or close personal friend ever been the subject of a wiretap or surveillance 

(visual, photographic, or electronic) by law enforcement or had their car or

home searched by law enforcement officers?

Yes No 

If yes, please explain. 

67. There may be evidence in this case about the activities of American and/or

foreign intelligence agencies. Do you have any strong feelings about American intelligence services or foreign intelligence services?

Yes No 

If yes, please explain. 
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68. What religious affiliations have you ever had? (List in chronological order 

with your current affiliation first.) 

69. How often do you attend religious services or engage in activities organized 

by a religious organization? (Check one category.)

At least daily

More than once a week

Once a week

A few times a month

A few times a year

Never

70. Have you ever experienced what you believe to be discrimination against you 

because of your religious beliefs?

Yes No 

If yes, please explain. 

71. Do you personally know anyone who is a student of, or practices, the Muslim 

or Islamic faith?

Yes No 

If yes, describe your relationship to that person and whether you have discussed that person s faith with him or her. 72. Do you have any feelings, positive or negative, about the Muslim or Islamic 

faith?

Yes No 

If yes, please describe them. 

73. How knowledgeable are you about the history or practices of the Muslim or

Islamic faith?

Very knowledgeable

Somewhat knowledgeable

Not too knowledgeable

Not at all knowledgeable
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74. Have you ever heard of the group Markaz Dawa Wa al Irshad, or Lashkar- e-Taiba or LET ?

Yes No 

If yes, please describe what you heard and the source. 

75. Have you ever heard the word jihad ?

Yes No 

If yes, what does it mean to you? 

76. Have you ever heard the word mujahideen ?

Yes No 

If yes, what does it mean to you? 

77. Have you ever heard the word Taliban ?

Yes No 

If yes, what does it mean to you? 

78. Do you have an opinion regarding the nature of the conflict between India

and Pakistan over Kashmir or of the present foreign policy of the United

States with respect to this dispute?

Yes No 

If yes, what is your opinion? 

79. Do you have an opinion regarding the nature of the conflict in Chechnya or

of the present foreign policy of the United States with respect to the conflict 

in Chechnya?

Yes No 

If yes, what is your opinion? 
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80. What is your opinion regarding the balance between church and state in the

United States today? Do you think that:

Too much consideration of religion is given in matters of 

government

Too little consideration of religion is given in matters of government

About the right consideration of religion is given in matters of 

government

Please explain. 

81. Do you believe that the rights and liberties of freedom of speech, freedom of

religion, and freedom of association guaranteed by the First Amendment of

the U.S. Constitution should ever be limited or restricted for any reason (for

example, in time of war)?

Yes No 

If yes, please explain. 

82. Do you believe that if the prosecution goes to the trouble of bringing someone to trial, he or she is probably guilty?

Yes No Unsure 

83. Do you believe that sometimes innocent people are convicted of crimes they

did not commit?

Yes No Unsure 

84. Do you believe that defendants in criminal trials should have to prove that

they are innocent?

Yes No Unsure 

85. Do you believe that the law does too much to protect the rights of criminal

defendants and not enough to protect the rights of crime victims and their

families?

Yes No Unsure 

86. Do you believe that if a defendant does not testify at trial he is probably

guilty?

Yes No Unsure 
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87. Would you evaluate the testimony of a criminal defendant in the same manner as you would the testimony of any other witness?

Yes No Unsure 

88. Do you tend to believe that a member of law enforcement, such as a police 

officer or a federal agent, who testifies in court is:

More likely to tell the truth than other witnesses

Less likely to tell the truth than other witnesses

Equally likely to tell the truth as other witnesses

89. At the conclusion of the case it is the Court s task and duty to charge you on

the law and explain to you the elements of the crimes charged in the indictment. Do you have personal, religious, philosophical, or other beliefs as to

what the law is or should be that would make it difficult for you to follow the 

instructions of the Court?

Yes No 

90. Is there anything about the nature of the charges in this case that would affect 

your ability to fairly evaluate the evidence regarding whether or not the government has proven the guilt of the defendant beyond a reasonable doubt?

Yes No 

If yes, please explain. 

91. Is there any reason why you could not be completely fair and impartial to the

defendant Dr. al-Timimi or to the Government in this case?

Yes No 

If yes, please explain. 

The trial will start on or about April 4, 2005, and will last approximately three

weeks. Most weeks, the jury will sit five (5) days per week, from approximately

9:30 a.m. to 6:00 p.m. On Fridays, there may be a shortened trial date. Jurors will 

be paid an attendance fee of $40 per day, and transportation costs will be reimbursed.

Jury service is one of the highest duties and privileges of a citizen. The participation of people like yourself is essential to the proper administration of justice. The Court recognizes that not everyone can serve on a case of this length. However, mere inconvenience or the usual financial hardships of jury service

will not be enough to excuse you. You must show that service in this case would

cause an unacceptable amount of personal hardship.
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92. Would you have a serious hardship if chosen for this case?

Yes No 

If yes, please explain the hardship. 

93. Do you have any problem with your hearing or vision or other medical condition that would make it difficult for you to serve as a juror?

Yes No 

If yes, please explain. 

94. Are you taking any medication that may interfere with your ability to concentrate or serve as a juror in any way?

Yes No 

If yes, please explain how the medication would interfere. 

95. Do you have any specific problems dealing with stress or pressure?

Yes No 

If yes, please explain. 

96. Is there anything else that you want to bring to the attention of the Court or

that you think the Court or the lawyers should know about you that may impact your jury service in this case or may influence your ability to fairly and

impartially judge the evidence in this case and to apply the law as instructed 

by the court?

Yes No 

If yes, please explain. 
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A F F I R M A T I O N

I, , hereby declare under penalty of

perjury that the foregoing answers set forth in this Jury Questionnaire are true

and correct to the best of my knowledge and belief. I have not discussed my answers with others, or received assistance in completing the questionnaire. I have

answered all of the above questions in this Jury Questionnaire myself. 

Executed in the Eastern District of Virginia, on this day of March, 2005. __________________________________ Signature 
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EXPLANATION SHEET

QUESTION NUMBER EXPLANATION
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EXPLANATION SHEET (CONTINUED)

QUESTION NUMBER EXPLANATION