1 

United States v. Amawi: 

Jury Questionnaire 

Hon. James G. Carr 

Northern District of Ohio 

March 4, 2008 

The following questionnaire was prepared by attorneys to facilitate jury selection 

in a prosecution for conspiracy to fight United States forces in Iraq, United States 

v. Amawi, No. 3:06-cr-719 (N.D. Ohio. Feb. 16, 2006), the Northern District of 

Ohio’s United States District Judge James G. Carr presiding. Judge Carr wishes 

he had given the questions greater scrutiny, because some proved to be too confusing to the potential jurors. 

Jury Questionnaire 

Your Full Name: ___________________________________________________ 

Please print legibly using dark ink. 

Preliminary Instructions: 

Please print your name and juror number in the space provided above on this 

page and your juror number at the top of each subsequent page. Please answer 

each question by placing an “X” next to your response or by providing the 

information requested. Please answer each question fully. Some questions have 

more than one part. 

You are sworn to give true and complete answers to all questions in this 

questionnaire. This questionnaire is designed to help simplify and shorten the 

jury selection process. The purpose of this questionnaire is to determine whether 

prospective jurors can impartially decide this case based upon the evidence presented at trial and the legal instructions given by the presiding judge. The questions are not intended to unnecessarily inquire into personal matters. Although 

some of the questions may appear to be of a personal nature, please understand 

that the Court and the parties must learn enough information about each juror’s 

background and experiences to select a fair and impartial jury. 

All information contained in this questionnaire will be kept confidential and 

under seal. The questionnaires belong to the Court and all copies will be returned 

to the Court. After reading your questionnaire, Chief Judge Carr, as well as some 

of the lawyers, may personally interview you and give you the opportunity to 

discuss your answers. 

Please answer all the questions to the best of your ability. If you have any 

questions, write them on the form. If you do not know the answer to a question, 

then write, “I don’t know.” There are no right or wrong answers, only truthful

answers. Do not discuss the case or your answers with anyone. It is important 
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that the answers be yours alone. Remember, you are sworn to give true and complete answers to all questions. 

The Court instructs you not to discuss the questions and answers with 

fellow jurors. It is very important that your answers be your own individual 

answers. 

Further, the Court instructs you not to discuss anything about this case with 

anyone: not the lawyers, your fellow jurors, your family, your friends, or anyone 

else. 

Summary of the Case 

This is a criminal case. The defendants, Mohammad Amawi, Marwan el-Hindi, 

and Wassim Mazloum, have been charged by way of an indictment. The indictment is not evidence. Its function is simply to put the defendants on notice of the 

charges that the government is required to prove to the jury beyond a reasonable 

doubt. The law presumes all defendants are innocent. 

This indictment alleges that the Defendants conspired to kill or maim persons outside of the United States and also that they conspired to provide material 

support to terrorists. The indictment further alleges that Mohammad Amawi and 

Marwan el-Hindi agreed to distribute information that would teach or demonstrate the making or use of an explosive or destructive device with the intent that 

the information be used in the furtherance of a Federal crime of violence. Finally, 

the indictment alleges that Mohammad Amawi twice threatened to take the life of 

or inflict bodily harm upon the President of the United States. 

Later in this questionnaire, you will be given an opportunity to state whether 

you believe you have read or seen media reports about this case or know any of 

the participants in this trial. 

You must keep in mind that each of the defendants is presumed innocent. 

This presumption of innocence stays with each defendant until and unless every 

element of each offense has been proved beyond a reasonable doubt by the government. 

Hardship 

Jury selection will being on Tuesday, March 4, 2008. The trial will commence in 

late March or early April 2008. Trial will be in session four days per week 

(Tuesday through Friday) from 8:30 a.m. to approximately 4:30 p.m. In addition 

to Mondays, there may be other scheduled court breaks. To be on the safe side, 

we are requiring that the jurors who serve on this case be available through the 

end of June, 2008. 

If you are selected as a juror, you will be required to be present for the taking of testimony for as long as the trial lasts. There are no plans to sequester the 

jury, which means you will go home every day after court. 
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You will receive $40 per day as a fee for your jury service for the first 30 

days of your service. For service beyond 30 days, you will receive $50 per day. 

You will also receive payment for parking and mileage. Other details have been 

or will be explained to you at juror orientation. 

The Court views service on a jury in a federal criminal trial to be one of the 

highest duties a citizen owes to the United States. Mere inconvenience or the 

usual financial hardship of jury service will not be sufficient to excuse a prospective juror. You must show extraordinary personal or financial hardship to be excused from service. 

1. Do you have any unusual financial or other hardship that would prevent you 

from serving as a juror in this case? 

 Yes _____ No _____ 

 (Even if you answered “yes,” you must still answer the entire questionnaire.) 

 If yes, please explain briefly the nature of the hardship: ________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 Will you be paid your salary while you serve on jury duty? 

 Yes _____ No _____ 

2. Is English your first language? 

 Yes _____ No _____ 

 If no, what is your first language? _________________________________ 

3. Do you have any difficulty speaking, reading, or understanding English? 

 Yes _____ No _____ 

 If yes, please explain: ___________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 
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4. Do you have any physical problems or disabilities (such as hearing, eyesight, high blood pressure, stomach ailments, headaches, back, hip, or neck 

problems) that would make it difficult for you to serve as a juror in this 

case? 

 Yes _____ No _____ 

 If yes, please explain: ___________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

5. Do you have any regularly scheduled treatments or therapies that would interfere with your ability to be in court daily? 

 Yes _____ No _____ 

 If yes, please explain: ___________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

6. Please note that the following question, like some other questions in this 

questionnaire, is not meant to be overly intrusive. It may be, however, that 

certain medications you take may impact on your ability to concentrate or 

reason. So that we might more fully understand, we ask for your full disclosure. 

 Are you currently taking any medication? 

 Yes _____ No _____ 

 If yes, please list the medications you take: __________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

7. Do these medications produce any side effects that might interfere with your 

ability to focus or concentrate? 

 Yes _____ No _____ 

 If yes, please tell us which medications and describe the side effects: _____ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 
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8. Do you have a vacation planned during the time anticipated for the trial for 

which you have prepaid or made a financial commitment? 

 Yes _____ No _____ 

 If yes, please explain: ___________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

9. Have you ever been under a doctor’s care for any of the following? 

a. Mental problems, including mood disorders? 

 Yes _____ No _____ 

b. Alcohol related problems? 

 Yes _____ No _____ 

c. Drug problems? 

 Yes _____ No _____ 

 If your answer is yes to any of the questions above, please explain: _______ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

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

 Yes _____ No _____ 

 If yes, please explain: ___________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

11. Are you a smoker? 

 Yes _____ No _____ 

 If yes, do you need to smoke more often than every two hours? __________ 

Whether or not you are claiming a hardship, 

you must complete the rest of this questionnaire. 

Background 

12. Are you: Female _____ Male _____ 

13. How old are you? _____ 
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14. What is your place of birth? (If outside the U.S., please tell us the city and 

country.) 

 City and State: _________________________ Country: _______________ 

15. Where were your parents born? 

 Mother: City and State: ________________ Country: _______________ 

 Father: City and State: ________________ Country: _______________ 

16. Are you, any member of your immediate family, or an in-law a naturalized 

U.S. citizen (formerly a citizen of another country and now a citizen of the 

U.S.)? 

 Yes _____ No _____ 

 Please tell us your relationship to the person and when, if you know, he or 

she became a citizen: ___________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

17. In what community do you live? 

 City/Township/Village: _________________________________________ 

 County: ______________________________________________________ 

18. Do you: 

 _____ Own your home 

_____ Rent 

_____ Neither own nor rent, but live with family/friend 

19. How long have you lived at your present address? ____________________ 

20. How long have you lived in northwestern Ohio? ______________________ 

21. In what other communities have you lived? __________________________ 

22. Are you: 

 _____ Married for _____ years 

_____ Single never been married 

_____ Divorced 

_____ Separated 

_____ Widowed 

_____ Living with someone 
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23. How would you describe your race, ethnicity, or national origin? 

 _____________________________________________________________ 

24. How would you describe the race, ethnicity, or national origin of your 

spouse or significant other? 

 _____________________________________________________________ 

25. Do you have any children, step children, or foster children? 

 Yes _____ No _____ 

 Please list: 

Age Male/Female Highest Level of 

Education 

Job/Occupation Live with 

you? Y/N 

 

Education 

26. What is the highest grade that you completed in school? Please check all 

appropriate answers: 

 Elementary/High School Grades: 

 _____ 1–7 _____ 8 _____ 9 _____10 _____ 11 _____ 12 

 College: 

 _____ 1 yr. _____ 2 yrs. _____ 3 yrs. _____4 yrs. 

 Please specify your college major or majors: _________________________ 

 If you obtained a college degree, please specify the type: _______________ 

 Graduate or professional school: Please specify the area of study and what 

degree you received, if any: ______________________________________ 

 Vocational/Technical School: 

 _____ 1 yr. _____ 2 yrs. _____ 3 yrs. _____4 yrs. 

 Type of vocation or technical training: ______________________________ 

27. If you did not graduate from high school, did you obtain a GED? _________ 
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28. What is the educational background of your spouse or domestic partner? 

 _____________________________________________________________ 

29. Have you or any member of your immediate family attended any school, 

college, or university in a country other than the United States? 

 Yes _____ No _____ 

 If yes, please describe: __________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

Employment/Vocational Training 

30. If you are currently employed, please tell us about your job: 

 Who is your employer? __________________________________________ 

 Do you work more than one job? __________________________________ 

 About how many hours do you work each week? _____________________ 

 What is your job description? _____________________________________ 

 Do you supervise other people? ___________________________________ 

 Do you have authority to hire and fire other people? ___________________ 

 How long have you worked at your job? ____________________________ 

 If you have held your job for less than ten years, what did you do 

previously? ___________________________________________________ 

 Have you ever been fired from a job? ______________________________ 

 If so, what were the reasons given for your firing? ____________________ 

31. If your spouse or domestic partner is employed outside the home, please tell 

us about his or her job: 

 Who is his or her employer? ______________________________________ 

 What is his or her job description? _________________________________ 

 Does he or she supervise other people? _____________________________ 

 How long has he or she worked at this job? __________________________ 

 If he or she held this job for less than ten years, what did he or she do 

previously? ___________________________________________________ 
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32. If you are retired: 

 Who was your last full-time employer? _____________________________ 

 How long did you work at that job? ________________________________ 

 What was your title or job description? _____________________________ 

 Did you supervise others? ________________________________________ 

 Did you have authority to hire and fire others? _______________________ 

 What other jobs or occupations did you have during your working years? 

 _____________________________________________________________ 

33. If your spouse is retired: 

 Who was his or her employer? ____________________________________ 

 How long did he or she work at that job? ____________________________ 

 What was his or her title or job description? _________________________ 

 Did he or she supervise other people? ______________________________ 

34. If you are not employed outside the home, are you: 

 _____ A student 

 Where do you attend school? _______________________________ 

 How many days a week do you attend? _______________________ 

 _____ A homemaker 

 _____ Between jobs 

 What is your usual employment? ____________________________ 

 _____ Disabled 

 What is the nature of the disability that prevents you from working? 

 _______________________________________________________ 

 How long has it been since you were last employed outside the 

 home? _________________________________________________ 
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35. Have you, or any member of your immediate family, ever owned a business, 

been a member of a partnership or served on the Board of Directors of any 

business, corporation, or organization, including non-profit or charitable organizations? 

 Yes _____ No _____ 

 If yes, please describe: __________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

36. How often would you say you seek out positions of leadership when you 

participate with others at work or in a group? Would you say: 

 _____ Always _____ Often _____ Sometimes _____ Seldom _____ Never 

Contact and Experience with the Legal System 

37. Have you ever served as a juror? 

 _____ Yes, at trial _____ Yes, on a grand jury _____ No 

 If you have served as a trial juror please provide the following information 

for each time you have served: 

Date/ 

Place 

Civil or 

Criminal 

State or 

Federal 

Charges/ 

Allegations 

Did the jury 

reach a verdict, and, if 

so, what was 

it? 

Were 

you the 

foreperson? 

 

38. Have you ever served on any type of case in which testimony from an expert 

witness was presented to the jury? 

 _____ Yes _____ No _____ Not applicable 

 If yes, what were the areas of expertise of the witnesses? _______________ 

 _____________________________________________________________ 

39. How did you feel about your service as a juror in a trial? _______________ 

 _____________________________________________________________ 
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40. Was there anything about your experience as a juror that would make you 

want or not want to serve again? 

 Yes _____ No _____ 

 Please explain your answer: ______________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

41. Please describe your general feelings about the following: 

a. Law Enforcement Officers: __________________________________ 

 _________________________________________________________ 

b. Prosecuting Attorneys: ______________________________________ 

 _________________________________________________________ 

c. Defense Attorneys: _________________________________________ 

 _________________________________________________________ 

d. Judges and Magistrates: _____________________________________ 

 _________________________________________________________ 

42. Have you ever attended law school? 

 Yes _____ No _____ 

 Did you graduate? 

 Yes _____ No _____ 

 If no, why not? ________________________________________________ 

 _____________________________________________________________ 

43. Other than law school, have you ever received any training or taken a course 

in law or law enforcement, including but not limited to paralegal training, 

criminal justice, investigation, business law, forensic accounting, criminology, or computer crime? 

 Yes _____ No _____ 

 If yes, please describe: __________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 
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44. Are you now or have you ever been a practicing attorney? 

 Yes _____ No _____ 

 If yes, please list any current or past admissions to state, federal, or any other court: ______________________________________________________ 

 _____________________________________________________________ 

 If yes, have you ever been disciplined or sanctioned by any state bar? Please 

explain: ______________________________________________________ 

 _____________________________________________________________ 

 If yes, please briefly describe the nature of your practice. Please include any 

experience in criminal law, including clerkships, internships, or pro bono activities _______________________________________________________ 

 _____________________________________________________________ 

45. Do you have any close friends or relatives who are lawyers or who have attended law school? 

 Yes _____ No _____ 

 If so, do they practice criminal law? 

 Yes _____ No _____ 

 If so, do they ever discuss their work with you? 

 Yes _____ No _____ 

46. Do you or does any relative or close friend work for a prosecutor, criminal 

defense lawyer, or private investigator? 

 Yes _____ No _____ 

 If so, do they ever discuss their work with you? 

 Yes _____ No _____ 

47. Do you know anyone who has been connected with the criminal justice system such as judges, law clerks, court attendants, court clerks, other types of 

court personnel, probation officers, or persons connected with any penal institution, jail, or penitentiary? 

 Yes _____ No _____ 

 If so, do they ever discuss their work with you? 

 Yes _____ No _____ 

Note: In the following questions, the Court is not looking to pry into the past history of jurors or their families but wants to be informed as to what experiences 
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each juror (or a loved one) has gone through in order to determine whether these 

prior experiences might color the juror’s perceptions of how the criminal justice 

system works. Thus, the following questions must be answered fully and candidly to ensure that the Court and the parties can make a proper determination of 

whether jurors would be particularly suited for the case. Please do not feel embarrassed about any questions, as the answers will be treated in strict confidence. 

48. Have you or anyone close to you, including a family member, friend, or acquaintance, ever been accused, arrested, charged, or convicted for a crime or 

been the subject of a criminal investigation? Please include any charges or 

accusations that were ultimately dismissed, expunged, sealed, or otherwise 

acquitted. 

 Yes _____ No _____ 

 If yes, please provide a brief description of the crime, the relationship of the 

person charged or accused, and the ultimate outcome: _________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 If yes, how do you feel about the behavior of any law enforcement officials, 

attorneys, or the courts in investigating or resolving the charges discussed 

above? _______________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 Do you feel that you (or your family member or friend) were treated fairly 

by the criminal justice system? Why or why not? _____________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 
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49. Whether or not you have had any personal experiences with the court system, do you believe that the U.S. court system treats people accused of a 

crime with fairness? 

 Yes _____ No _____ 

 If no, please explain: ____________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

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

proceeding? 

 Yes _____ No _____ 

 If yes, please explain: ___________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

51. Have you ever had to appear in court, or in any legal proceeding, as a plaintiff, defendant, victim, or witness for any reason other than that explained 

above? 

 Yes _____ No _____ 

 If yes, please explain: ___________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 
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52. Have you or anyone close to you, including a family member, friend, or acquaintance ever been the victim of or witness to a crime? 

 Yes _____ No _____ 

 If yes, please provide a brief description of the crime, the relationship of the 

person who was the victim or witness, whether that crime was reported to 

the police, whether anyone was arrested for that crime, and the outcome of 

the case: _____________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 Do you feel that you (or your family member or friend) were treated fairly 

by the criminal justice system as a victim of or a witness to a crime? Why or 

why not? _____________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

53. Have you or anyone close to you, including a family member, friend, or acquaintance, ever worked for or applied for employment with any private, local, state, or federal law enforcement agency? 

 Yes _____ No _____ 

 If yes, please identify who, the agency, the position of employment, and the 

length of employment: __________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

54. If you indicated yes to the previous question, is there anything about that 

experience, or your association with someone with that experience, that 

would affect your ability to serve as a fair and impartial juror in this case? 

 Yes _____ No _____ 

 If yes, please explain: ___________________________________________ 

 _____________________________________________________________ 
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55. Would you tend to give more or less weight to the testimony of a law enforcement officer as opposed to any other witness? 

 _____ More weight _____ Less weight _____ Equal weight 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

56. Are you a vendor or contractor for the United States Government, or do you 

work with one? 

 Yes _____ No _____ 

 If yes, please explain the relationship to you and the circumstances: ______ 

 _____________________________________________________________ 

 _____________________________________________________________ 

57. Have you or anyone close to you ever worked in an effort to change a law or 

the enforcement of a law? 

 Yes _____ No _____ 

 If yes, please explain how you participated: __________________________ 

 _____________________________________________________________ 

58. Have you, a family member, or a close friend made or brought any claims or 

lawsuits against any federal, state, district, or governmental agency? 

 Yes _____ No _____ 

 If yes, please explain: ___________________________________________ 

 _____________________________________________________________ 

59. Have any claims or lawsuits ever been made by any federal, state, district, or 

local official or government agency against you, a family member, or close 

friend? 

 Yes _____ No _____ 

 If yes, please explain: ___________________________________________ 

 _____________________________________________________________ 

60. Which statement most accurately reflects your position: “If I learned that a 

witness had previously used illegal drugs, I would . . .” 

 _____ Discredit all of that witness’s testimony regardless of the circumstances of the drug use and the evidence in the case. 

 _____ Consider the witness’s testimony in light of the circumstances of the 

drug use combined with the evidence in the case. 
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61. You may hear testimony in this case concerning the use of cooperating witnesses by federal authorities. One or more of those individuals may be 

called to testify in this case. Do you have strongly held feelings for or 

against the use of cooperating witnesses? 

 Yes _____ No _____ 

 Please explain _________________________________________________ 

 _____________________________________________________________ 

62. Would your answer to the above question change if the witness was paid for 

being a cooperating witness? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

63. Do you believe that the testimony of a person who receives benefits from 

the government for cooperation should be viewed with more caution than 

another witness? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

64. Do you believe that a person who is being paid by the government to be a 

cooperating witness is a “snitch”? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

65. There may be photographic evidence presented in this case downloaded 

from the Internet that graphically depicts acts of violence. How do you think 

that evidence would affect you? ___________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

66. Does your reaction to photographic evidence change if the images are video 

rather than a still picture? 

 Yes _____ No _____ Unsure ______ 
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67. Do you think it should be illegal for a person to possess or own pictures or 

videos of graphic violence and death? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

68. There may be evidence in this case consisting of recordings of conversations 

taking place over the telephone or face-to-face through the use of recording 

devices. Do you have any favorable or unfavorable views about the use of 

such evidence? 

 Yes _____ No _____ 

 If yes, please explain: ___________________________________________ 

 _____________________________________________________________ 

69. There may also be evidence obtained from photographic and physical surveillance and evidence obtained from various places, including the homes of 

the defendants and others. Do you have favorable or unfavorable views 

about the use of evidence obtained through such surveillance or search? 

 Yes _____ No _____ 

 If yes, please explain: ___________________________________________ 

 _____________________________________________________________ 

70. To your knowledge, have you, or any close friend or relative, even been a 

subject of a surveillance (visual, photographic, or electronic) or had their car 

or home searched by law enforcement officers? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 
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Military Experience 

71. Have you ever served in the U.S. military, including the Coast Guard, Reserves, or National Guard? 

 Yes _____ No _____ 

 If yes, please provide details, including (1) the approximate dates of service, 

(2) the branch of service in which you serve or served, (3) your highest rank 

attained, (4) all duty locations, (5) your job description, (6) whether you 

served in a combat zone, and (7) the type of discharge: _________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

72. Have you ever served in the military or paramilitary (police, security services, militia, etc.) of any other nation, state, or political entity? 

 Yes _____ No _____ 

 If yes, please describe: __________________________________________ 

 _____________________________________________________________ 

73. Has anyone in your family or close to you ever served in the U.S. military, 

including the Coast Guard, Reserves, or National Guard? 

 Yes _____ No _____ 

 If yes, please provide details, including (1) the approximate dates of service, 

(2) the branch of service in which they serve or served, (3) their highest rank 

attained, (4) all duty locations, (5) their job description, (6) whether they 

served in a combat zone, and (7) the type of discharge: _________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

74. Do you know anyone who has been injured or killed while serving in a 

combat or militarized zone? 

 Yes _____ No _____ 

 If yes, please explain their relationship to you and, if you can, the circumstances of their injury or death: ____________________________________ 

_____________________________________________________________ 
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75. Have you or anyone you know worked or volunteered in a civilian or nonmilitary government capacity anywhere in the Middle East? 

 Yes _____ No _____ 

 If yes, please explain their relationship to you and, if you can, the circumstances of their volunteering: ______________________________________ 

 _____________________________________________________________ 

76. What are your thoughts or feelings about serving as a juror on a case involving terrorism-related charges? ____________________________________ 

 _____________________________________________________________ 

77. Have you, any member of your family, a co-worker, or a close personal 

friend been directly affected in any way by an act of terrorism? 

 Yes _____ No _____ Unsure _____ 

 If yes or unsure, please describe: __________________________________ 

 _____________________________________________________________ 

78. Have you read any books or articles or seen any media (movies, cable 

shows, documentaries, blogs, or plays) depicting or describing the events of 

9/11 or U.S. military efforts to combat terrorism? 

 Yes _____ No _____ Unsure _____ 

 If yes or unsure, please describe: __________________________________ 

 _____________________________________________________________ 

79. Would your knowledge, experience, or opinion on the issue of terrorism, or 

the opinion of your family members or close personal friends on terrorism, 

make it difficult for you to sit on a jury in a case of this kind? 

 Yes _____ No _____ Unsure _____ 

 If yes or unsure, please describe: __________________________________ 

 _____________________________________________________________ 

Knowledge and Opinions of Case and Parties 

80. This case has received publicity in the local media. There is nothing wrong 

with having heard something about this case. What do you recall seeing or 

hearing, from any source, about this case? ___________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 
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81. Please indicate whether you have heard anything about this case, the 

charges, or any of the defendants in the case from any of the following 

sources (check as many as apply): 

 _____ Television 

_____ Radio 

_____ Newspaper 

_____ Internet/online 

_____ News magazines 

_____ Conversations with family members 

_____ Conversations with coworkers, friends, or neighbors 

_____ Conversations with persons at the courthouse 

_____ Overheard conversations in the community 

_____ Overheard conversations at the courthouse 

82. How would you describe your knowledge of this case? 

 _____ Very knowledgeable 

_____ Somewhat knowledgeable 

_____ Not very knowledgeable 

_____ No knowledge at all 

83. Have you seen, read, or heard about the following people facing charges in 

this case? Please check all that you might have heard about: 

 _____ Mohammad Amawi 

_____ Marwan el-Hindi 

_____ Wassim Mazloum 

84. Have you read about any statements made by or attributed to Mohammad 

Amawi, Marwan el-Hindi, or Wassim Mazloum? 

 Yes _____ No _____ Unsure _____ 

 If yes or unsure, what did you read, see, or hear that you think might be 

connected to this case (even if you are not sure exactly where you heard it)? 

 _____________________________________________________________ 

 _____________________________________________________________ 

 Please indicate to whom the statement was attributed: _________________ 

 _____________________________________________________________ 
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85. Do you know or have you had any contact whatsoever with any of the following individuals who may be referenced in this case? Please check all that 

apply: 

 _____ Zubair Ahmed 

_____ Khaleel Ahmed 

_____ Mohammed Ahmed 

_____ Yasmeen Ahmed 

_____ Ashraf Zaim 

_____ Bilal Mazloum 

86. Do you know any of your fellow perspective jurors? 

 Yes _____ No _____ Unsure _____ 

 If yes or unsure, please describe: __________________________________ 

 _____________________________________________________________ 

87. 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 be advising you periodically that you must avoid reading 

about the case in the newspapers or listening to any radio or television reports about the case. The Court will also advise you periodically that you 

must avoid discussing this case with friends or family during the course of 

the trial. Would these requirements pose any difficulty for you? 

 Yes _____ No _____ Unsure _____ 

 If yes or unsure, please describe the difficulty you would have avoiding media or discussing the case with family or friends: ______________________ 

 _____________________________________________________________ 

88. a. If you were chosen to serve as a juror in this case do you think that 

your family and friends would try to influence you with their feelings 

and opinions about cases involving allegations of terrorism? 

 Yes _____ No _____ 

 Please explain: ____________________________________________ 

b. If you were to serve as a juror in the case would you feel pressured or 

embarrassed to explain to your family and friends your vote of guilty or 

not guilty? 

 Yes _____ No _____ 

 Please explain: ____________________________________________ 
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89. Do you know any of the attorneys representing the United States government that are prosecuting this case? 

 _____ David I. Miller 

_____ Gregg N. Sofer 

_____ Thomas E. Getz 

_____ Jerome J. Teresinski 

_____ Justin Herdman 

90. Do you know any of the defense lawyers representing the men on trial in 

this case? 

 Attorneys for Mohammad Amawi 

 _____ William W. Swor 

_____ Elias Muawad 

_____ Ed Bryan 

_____ Tim Ivey 

_____ Amy Cleary 

_____ Jonathan Witmer-Rich 

_____ Dennis Terez 

 Attorneys for Marwan el-Hindi 

 _____ Charles M. Boss 

_____ Stephen D. Hartman 

_____ Alek H. el-Kamhawy 

 Attorneys for Wassim Mazloum 

 _____ David L. Doughten 

_____ Jeffrey J. Helmick 

_____ Mohammed Abdrabboh 

Organizations, Activities, and Interests 

91. What civic, social, political, or recreational groups do you belong to or participate in, and what offices, if any, do you hold in any of these organizations? _______________________________________________________ 

 _____________________________________________________________ 

92. Are you, your spouse, an immediate family member, or a close friend involved in any organized political activities? 

 Yes _____ No _____ 

 Please describe: _______________________________________________ 

 _____________________________________________________________ 
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93. Have you, any member of your family, or any close personal friend ever 

held an elected or appointed office in the federal, state, or local government? 

 Yes _____ No _____ 

 If yes, please describe: __________________________________________ 

 _____________________________________________________________ 

94. To what organizations have you donated money, even if you are not a member? _________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

95. Do you consider yourself to be politically: 

 _____ Very conservative 

_____ Conservative 

_____ Moderate 

_____ Liberal 

_____ Very liberal 

_____ Independent 

96. About which of the following national issues are you most concerned? 

 _____ Economic conditions 

_____ Health Care 

_____ The Iraq situation 

_____ Illegal immigration 

_____ Terrorism 

_____ Education 

_____ Other (please specify): _____________________________________ 

97. Name three public figures you admire most, and please tell us why? 

 (1) __________________________________________________________ 

 (2) __________________________________________________________ 

 (3) __________________________________________________________ 

98. Name three public figures you admire least, and please tell us why? 

 (1) __________________________________________________________ 

 (2) __________________________________________________________ 

 (3) __________________________________________________________ 

99. How would your close friends and relatives describe you? ______________ 

 _____________________________________________________________ 
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100. What are your favorite leisure activities, hobbies, and interests? __________ 

 _____________________________________________________________ 

101. Have you ever received any training or taken any courses in martial arts or 

weapons training? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

102. Do you read books in your spare time? 

 Yes _____ No _____ 

 What type of books do you enjoy? _________________________________ 

 What was the last book you read? _________________________________ 

103. Do you have any bumper stickers or decals on any of your family cars or 

trucks? 

 Yes _____ No _____ 

 If yes, please tell us what they say: ________________________________ 

 _____________________________________________________________ 

Media 

104. From what sources do you receive your news on current events? 

 Please list all types of sources (for example, television, newspapers, magazines, journals, radio, the Internet, etc.), and state with particularity which 

sources (for example, CNN, Fox News, The Toledo Blade, New York 

Times, Wall Street Journal, Time, Newsweek, etc.): ___________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

105. Which of the above is your main source of news and information? ________ 

 _____________________________________________________________ 

106. Do you ever listen to radio talk shows or political commentators on TV or 

the radio, or ever visit political blog sites on the Internet? 

 Yes _____ No _____ 

 If yes, which ones? _____________________________________________ 

 _____________________________________________________________ 
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107. Have you ever called a radio or TV show or appeared on one to express your 

opinion on an issue? 

 Yes _____ No _____ 

 If yes, please tell us what show and what you called about: _____________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

108. Do you believe that the American news media provide accurate coverage of 

world events? 

 Yes _____ No _____ Unsure _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

109. What television (broadcast or cable) shows do you watch most often? 

 _____________________________________________________________ 

110. Do you own a computer? 

 Yes _____ No _____ 

 If yes, what do you primarily use your computer for? __________________ 

111. Have you ever used the Internet? 

 Yes _____ No _____ 

 How often? ___________________________________________________ 

 If yes, what do you do on the Internet? (Check all that apply.) 

 _____ Email 

_____ Surfing the Web 

_____ Paying bills 

_____ Shopping 

_____ Getting news 

_____ Playing games 

_____ Keeping in touch with friends 

_____ Other (describe): _________________________________________ 

112. Have you ever watched a video clip on your computer (for example, on 

“You Tube”)? 

 Yes _____ No _____ 
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113. Have you ever read a blog on the internet? 

 Never _____ Often _____ Every once in a while _____ 

 If so, which ones? ______________________________________________ 

 _____________________________________________________________ 

114. Have you or any member of your family chatted or corresponded online (for 

example, using chat rooms, blogs, or bulletin boards) with any individual or 

member of a group that shared an interest with you (for example, medical 

issues, gardening, or other hobbies or special interests)? 

 Yes _____ No _____ 

 If yes, please describe generally (but do not use personal identifiers like 

your screen names): ____________________________________________ 

 _____________________________________________________________ 

115. Do you think there should be any restrictions on the type of political material that can be viewed or transmitted on the Internet? 

 Yes _____ No _____ 

 Please describe: _______________________________________________ 

 _____________________________________________________________ 

Language Skills 

116. Do you speak any language other than English? 

 Yes _____ No _____ 

 If yes, please tell us what language and rate, as best you can, your 

proficiency: ___________________________________________________ 

 _____________________________________________________________ 

117. Do you, or anyone you know, speak, write, or understand the Arabic language (or any dialect of Arabic)? 

 Yes _____ No _____ Unsure _____ 

 If yes or unsure, please explain: ___________________________________ 

 _____________________________________________________________ 

 If yes, do you read any Arabic language newspapers or publications? 

 Yes _____ No _____ 

 If yes, please list the names: ______________________________________ 

 _____________________________________________________________ 
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118. Do you watch any Arabic language television stations? 

 Yes _____ No _____ 

 If yes, please list: ______________________________________________ 

119. Have you ever worked as a translator or an interpreter? 

 Yes _____ No _____ 

120. Have you or anyone you know ever had an experience in which you relied 

on a translator or an interpreter? 

 Yes _____ No _____ 

 If yes, please tell us about that experience: __________________________ 

 _____________________________________________________________ 

Religion 

121. In what religion, if any, were you raised? ___________________________ 

122. What is your current religious affiliation or denomination, if any? ________ 

 _____________________________________________________________ 

123. Do you belong to or do you attend any particular church, synagogue, 

mosque, or other religious organization? 

 Yes, currently _____ Yes, in the past _____ No _____ 

124. About how many times per month do you attend religious services of any 

kind? _______________________________________________________ 

125. How important would you say your faith is in your life? 

 _____ Very important 

_____ Somewhat important 

_____ Important 

_____ Not very important 

_____ Not important at all 

126. Is there anything about your religious beliefs that prevents you from sitting 

in judgment of another person? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 
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127. Is there anything about your religious beliefs that prevents you from sitting 

in judgment of persons of the Muslim faith (Islam)? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

128. a. Have you ever donated time or money to any charities or organizations 

that provide aid to people living either inside or outside the United 

States? 

 Yes _____ No _____ 

b. If yes, what are the names of the organizations and charities? ________ 

 _________________________________________________________ 

 In which countries or regions did these charities or organizations provide 

aid? _________________________________________________________ 

 _____________________________________________________________ 

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

you because of your religious beliefs, national origin, or race? 

 Yes _____ No _____ 

 If yes, please explain: ___________________________________________ 

 _____________________________________________________________ 

Firearms Experience 

130. Are you a member or supporter of any group that is either for or against gun 

control or firearm ownership (such as the National Rifle Association)? 

 Yes _____ No _____ 

 If yes, please list the organizations to which you belong: _______________ 

 _____________________________________________________________ 

131. Have you ever received any type of firearm training or any training in the 

use of a firearm? 

 Yes _____ No _____ 

 If yes, please tell us the weapons on which you trained and from whom you 

received the training: ___________________________________________ 

 _____________________________________________________________ 
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132. Does anyone in your household currently own any firearms? (Check all that 

apply.) 

 Yes, I do _____ Yes, someone else in the household _____ No _____ 

 If yes, please tell us how many and what types of firearms and the reasons 

for ownership: _________________________________________________ 

 _____________________________________________________________ 

133. Have you ever been to a shooting range? 

 Yes _____ No _____ 

 If yes, how often have you gone? __________________________________ 

134. Have you ever visited Cleland’s Outdoor World (formerly “Cleland’s Gun 

Shop”) in Swanton, Ohio? 

 Yes _____ No _____ 

 If yes, on how many occasions and for what purpose? _________________ 

 _____________________________________________________________ 

Opinions on Racial Issues 

135. Is there any racial or ethnic group that you do not feel comfortable being 

around? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

136. Have you ever had a bad experience with others as a result of racial or ethnic tension? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

137. Have you ever moved out of a neighborhood or community because of racial issues? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 
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Travel and Immigration 

138. Have you ever traveled outside the United States (excluding trips to Canada 

and Mexico)? 

 Yes _____ No _____ 

 If yes, please list to where you traveled, for how long you stayed, and for 

what purpose you took the trip: ___________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

139. Have you ever lived outside the United States? 

 Yes _____ No _____ 

 If yes, please list where you lived, for how long you lived there, and why 

you lived there: ________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

140. Do you know anyone who holds a dual citizenship in the U.S. and another 

country? 

 Yes _____ No _____ 

 If yes, please tell us your relationship to the person and in what other country he or she holds citizenship: ____________________________________ 

 _____________________________________________________________ 

141. Have you ever known anyone from another country who worked in the 

United States and had to have a green card or permit to continue working 

here? 

 Yes _____ No _____ 

 If yes, please explain: ___________________________________________ 

 _____________________________________________________________ 

142. What is your opinion about people coming from other countries to the United States to attend school? _______________________________________ 

 _____________________________________________________________ 
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143. Have you ever known anyone from another country who came to the United 

States to attend school or college? 

 Yes _____ No _____ 

 If yes, please explain: ___________________________________________ 

 _____________________________________________________________ 

144. In general, what are your feelings about people immigrating to the United 

States? _______________________________________________________ 

 _____________________________________________________________ 

145. Please check the option below that best reflects your opinion of the following statement: “The United States is too lenient with its immigration policies.” 

 _____ Agree strongly 

_____ Agree somewhat 

_____ Disagree somewhat 

_____ Disagree strongly 

_____ Don’t know 

_____ No opinion 

146. Do you think that English should be the “official language” of this country? 

 Yes _____ No _____ 

 Please explain your answer: ______________________________________ 

 _____________________________________________________________ 

147. Do you believe that the protections of free speech should extend to both citizens and non-citizens? 

 Yes _____ No _____ Unsure _____ 

 If yes or unsure, please explain: ___________________________________ 

 _____________________________________________________________ 

148. Have you ever contributed money or volunteered your time to any organization that opposes immigration, opposes certain rights to immigrants, or proposes changes in immigration laws? 

 Yes _____ No _____ 

 If yes, what organization? ________________________________________ 

 _____________________________________________________________ 
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Opinions on National Security 

149. Since September 11, 2001, how do you feel about the nation’s security 

measures to protect us from terrorism? 

 _____ Very satisfied 

_____ Somewhat satisfied 

_____ Somewhat dissatisfied 

_____ Very dissatisfied 

_____ Don’t know 

150. How often do you worry that you or a family member will be the victim of 

terrorism? 

 _____ Often 

_____ Occasionally 

_____ Rarely 

_____ Never 

151. How concerned are you about acts of terrorism happening in your local 

community? 

 _____ Very concerned 

_____ Somewhat concerned 

_____ Not very concerned 

_____ Not concerned at all 

152. Please check the option below that best reflects your opinion of the following statement: “Of all the issues facing the United States, I believe terrorism 

is the most important.” 

 _____ Agree strongly 

_____ Agree somewhat 

_____ Disagree somewhat 

_____ Disagree strongly 

_____ Don’t know 

_____ No opinion 

153. Do you believe there are terrorist “sleeper cells” in the United States? 

 Yes _____ No _____ Unsure _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 
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154. On a scale of 1 to 10 (with 1 being not likely at all and 10 being very likely), 

do you feel that the United States is currently vulnerable to a terrorist attack 

from within our own borders? Please circle the number that best rates your 

feelings: 

 Not at all Very likely 

 1 2 3 4 5 6 7 8 9 10 

155. Do you believe that defendants accused of violating federal criminal laws 

relating to terrorism should not be given the same rights as criminal defendants accused of violating other federal criminal laws not related to terrorism? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

156. Which comes closer to your view: 

 _____ The government should take all steps necessary to prevent additional 

acts of terrorism in the U.S., even if it means basic civil liberties 

would be violated. 

 _____ The government should take all steps necessary to prevent additional 

acts of terrorism in the U.S., but not if those steps would violate basic civil liberties. 

157. Have you followed any criminal cases locally or nationally? 

 Yes _____ No _____ 

 If yes, please describe which cases: ________________________________ 

 _____________________________________________________________ 

158. Have you followed any of the criminal cases in the United States involving 

allegations of terrorism or the support of terrorism? 

 Yes _____ No _____ 

 If yes, which cases did you follow and what was of interest to you about 

those cases? __________________________________________________ 

 _____________________________________________________________ 
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159. Do you have an opinion of how people accused of terrorism have been 

treated by the U.S. court system? 

 Yes _____ No _____ 

 If yes, what is it? _______________________________________________ 

 _____________________________________________________________ 

160. Have you ever visited any website produced by any media group or organization that attempts to monitor political events occurring in countries such 

as Iraq, Afghanistan, Pakistan, or other places in the Middle East? 

 Yes _____ No _____ 

 If yes, please describe: __________________________________________ 

 _____________________________________________________________ 

161. In the interest of national security and the prevention of terrorist attacks, do 

you think all adults in this country should be required to carry a national 

identification card? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

162. Have you ever heard the word “jihad”? 

 Yes _____ No _____ Unsure _____ 

 What do you understand “jihad” to mean? ___________________________ 

 _____________________________________________________________ 

Muslims/Islam 

163. Do you have any personal experience or knowledge of other countries or 

regions in which Islam is the predominant religion? 

 Yes _____ No _____ 

 If yes, please explain: ___________________________________________ 

 _____________________________________________________________ 

164. Have you ever received any training or taken any courses in Middle Eastern 

history, religion, Islamic law or international studies? 

 Yes _____ No _____ 

 If yes, please describe: __________________________________________ 

 _____________________________________________________________ 
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165. Have you, any member of your family, or a friend had any experience which 

would cause you to be biased for or against a defendant in a case who is an 

Arab or a Muslim? 

 Yes _____ No _____ 

 If yes, please explain: ___________________________________________ 

 _____________________________________________________________ 

166. Do you have any experiences or feelings about Arabs or Muslims that would 

make it difficult for you to listen to the evidence and decide a case with an 

open mind, when the case involves Arab or Muslim men charged with conspiring to kill or maim persons outside of the United States? 

 Yes _____ No _____ Unsure _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

167. Do you have any feelings, positive or negative, about Islam? 

 Yes _____ No _____ Unsure _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

168. Have you, any relative, or a friend had any dealings with any Muslim or Islamic organization? 

 Yes _____ No _____ 

 If yes, please explain: ___________________________________________ 

 _____________________________________________________________ 

169. Do you know or have regular contact with any person from a Middle Eastern background? 

 Yes _____ No _____ Unsure _____ 

 If so, please check all that apply: 

 _____ In the family 

_____ In the neighborhood 

_____ In organizations 

_____ Through work or business 

_____ In place of worship 

_____ In school 
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170. Do you know any Muslims (persons who practice the faith of Islam)? 

 Yes _____ No _____ 

 If yes, what is your relationship with them? __________________________ 

 _____________________________________________________________ 

171. How knowledgeable are you about the history or practices of Islam? 

 _____ Very knowledgeable 

_____ Somewhat knowledgeable 

_____ Not too knowledgeable 

_____ Not knowledgeable at all 

_____ Don’t know 

_____ No opinion 

172. Does the appearance of a person of apparent Arabic descent with a long 

beard or traditional dress make you uncomfortable? 

 Yes _____ No _____ Unsure _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

173. Do you think that because the men who planned and carried out the attack 

on 9/11 were Muslim that you will view the Muslim defendants in this case 

differently from how you would view any other defendant? 

 Yes _____ No _____ Unsure _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

174. Please check the option below that best reflects your opinion of the following statement: “Muslims as a group are being viewed in a negative way because of the actions of radical fundamentalists who do not represent the 

views of the majority of Muslims throughout the world.” 

 _____ Agree strongly 

_____ Agree somewhat 

_____ Disagree somewhat 

_____ Disagree strongly 

_____ Don’t know 

_____ No opinion 
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175. As a result of the events of 9/11, do you believe young Muslim and Middle 

Eastern men living in the United States had any reason to feel concern for 

their safety and the safety of their families? 

 Yes _____ No _____ Unsure _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

176. Do you believe there is any prejudice against or fear of Muslims or persons 

of Arab descent among the people living in the various communities in or 

around Northwest Ohio? 

 Yes _____ No _____ Unsure _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

Beliefs about Civil Liberties and Legal Protections 

177. Do you believe the U.S. Constitution should allow citizens and non-citizens 

residing in the U.S. to criticize the actions of the United States in writing, 

through non-violent demonstrations, or personal conversations, without restrictions? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

178. Can a person criticize the United States government and still be patriotic? 

 Yes _____ No _____ Unsure _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

Legal Principles 

179. An indictment is a document that merely describes the charges with which a 

defendant is accused. This means that the indictment may not be considered 

as any evidence whatsoever of any defendant’s guilt. 

 Do you agree or disagree with this rule of law? 

 Agree _____ Disagree _____ 

 If you disagree, please explain: ___________________________________ 

 _____________________________________________________________ 
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180. The defendants, Mohammad Amawi, Marwan el-Hindi, and Wassim Mazloum are presumed innocent and cannot be found guilty of any offense unless the jury, unanimously and based solely on the evidence presented in 

court, decides that the government has proved each element of each offense 

charged against each individual beyond a reasonable doubt. The burden of 

proving guilt beyond a reasonable doubt rests entirely with the government. 

The defendants are not required to prove their innocence. 

 Do you agree or disagree with this rule of law? 

 Agree _____ Disagree _____ 

 If you disagree, please explain: ___________________________________ 

 _____________________________________________________________ 

181. The law does not require the government to prove any essential element of 

the charged crimes beyond all doubt, or by some other standard higher than 

beyond a reasonable doubt. Do you believe that the government should be 

required to meet a standard of proof higher than “beyond a reasonable 

doubt”? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

182. If the government proves a defendant guilty of each essential element of one 

or more of the offenses charged by proof beyond a reasonable doubt, would 

you be able to return a verdict of guilty? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

183. The law requires that you put aside any sympathy that you might feel toward 

any of the defendants and decide this case solely on the evidence admitted at 

trial and the legal instructions provided by the Court. Would you be able to 

do this? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 
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184. The Court will instruct you that you are not to take into account any possible 

punishment or sentence in your deliberations as a juror. Can you deliberate 

regarding the evidence in this case without knowing what sentence the defendants face if found guilty of one or more of the offenses charged? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

185. The law requires that each of the defendants be given separate consideration 

and the case against each must be decided individually and solely on the 

evidence presented in court. Do you feel that, for whatever reason, you 

would not be able to consider each defendant individually? 

 Yes _____ No _____ Unsure _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

186. Under the law, a person accused of a crime does not have to testify in his or 

her defense. The defendants have the absolute right to not testify, and their 

silence may not be used against them. 

 Do you agree or disagree with this rule of law? 

 Agree _____ Disagree _____ 

 If you disagree, please explain: ___________________________________ 

 _____________________________________________________________ 

Final Questions 

187. During your introduction to the parties and lawyers today, you were read a 

list of names of possible witnesses. Do you believe you may know any of 

those witnesses? 

 Yes _____ No _____ Unsure _____ 

 If yes or unsure, please describe who you believe you know and how you 

know them: ___________________________________________________ 

 _____________________________________________________________ 

188. If during trial you learned you did know a witness, would you be willing to 

notify the Court and share the information? 

 Yes _____ No _____ 
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189. Do you know any other prospective juror who has been called for jury selection in this case? 

 Yes _____ No _____ 

 If yes, whom do you know? ______________________________________ 

 _____________________________________________________________ 

190. As a result of filling out this questionnaire, have you now formed an opinion 

about the case? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

191. Is there anything about the subject matter of this case, or the points covered 

in this questionnaire, which creates a question in your mind as to whether 

you could be a fair, objective, and impartial juror in this particular case? 

 Yes _____ No _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

192. Do you have any personal reason for wanting to serve as a juror in this case? 

 Yes _____ No _____ Unsure _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

193. Is there any reason that you could not be fair and impartial as to each of the 

defendants in this case? 

 Yes _____ No _____ Unsure _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 

194. Is there any reason that you could not be completely fair and impartial to the 

government in this case? 

 Yes _____ No _____ Unsure _____ 

 Please explain: ________________________________________________ 

 _____________________________________________________________ 
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195. If your view differs from the law upon which the Court instructs you, can 

you put aside your view and follow the Court’s instruction? 

 Yes _____ No _____ 

 If no, please explain: ____________________________________________ 

 _____________________________________________________________ 

196. Is there any matter not covered by the questionnaire that you feel you should 

tell us about? 

 Yes _____ No _____ 

 If yes, please explain: ___________________________________________ 

 _____________________________________________________________