National Security Prosecutions

Jury Questionnaires

and Preliminary Remarks

to Prospective Jurors

Federal Judicial Center

March 2011

This Federal Judicial Center publication was undertaken in furtherance of the Center s

statutory mission to develop and conduct education programs for the judicial branch. Views expressed herein are not necessarily those of the Federal Judicial Center.

iii

Table of Contents

Introduction ....................................................................................................................... v

United States v. Ghailani (American Embassies in Kenya and Tanzania):

Lewis A. Kaplan, S.D.N.Y.

Preliminary Remarks to Venire (September 23, 2010) ............................................... 1

Jury Questionnaire (September 22, 2010) .................................................................. 4

United States v. Shnewer (Fort Dix): Robert B. Kugler, D.N.J.

Jury Questionnaire (September 29, 2008) ................................................................ 14

United States v. Sadequee (Atlanta): William S. Duffey, Jr., N.D. Ga.

Jury Questionnaire (September 29, 2008) ................................................................ 54

United States v. Holy Land Foundation (Prosecution of a Charity):

Jorge A. Solis, N.D. Tex.

Confidential Jury Questionnaire (September 4, 2008) ............................................. 88

United States v. Amawi (Toledo): James G. Carr, N.D. Ohio

Jury Questionnaire (March 4, 2008) ....................................................................... 102

United States v. Batiste (Sears Tower): Joan A. Lenard, S.D. Fla.

Voir Dire Questions (September 18, 2007) ............................................................ 144

United States v. Holy Land Foundation (Prosecution of a Charity):

A. Joe Fish, N.D. Tex.

Confidential Jury Questionnaire (July 16, 2007) .................................................... 152

United States v. Sabir: Loretta A. Preska, S.D.N.Y.

Jury Questionnaire (April 24, 2007) ....................................................................... 166

United States v. Moussaoui (Twentieth Hijacker): Leonie M. Brinkema, E.D. Va.

Preliminary Venire Instructions (February 6, 2006) ............................................... 187

Jury Questionnaire (February 6, 2006) ................................................................... 191

United States v. Abu Ali (A Plot to Kill President Bush):

Gerald Bruce Lee, E.D. Va.

Preliminary Venire Instructions (October 25, 2005) .............................................. 237

Jury Questionnaire (October 25, 2005) ................................................................... 244

United States v. Al-Timimi (Paintball): Leonie M. Brinkema, E.D. Va.

Jury Questionnaire (March 28, 2005) ..................................................................... 271

United States v. Koubriti (Detroit): Gerald E. Rosen, E.D. Mich.

Preliminary Voir Dire (March 18, 2003) ................................................................ 295

Jury Questionnaire (March 18, 2003) ..................................................................... 301

United States v. El-Hage (American Embassies in Kenya and Tanzania):

Leonard B. Sand, S.D.N.Y.

Jury Questionnaire (January 3, 2001) ..................................................................... 326

United States v. Abdel Rahman (First World Trade Center Bombing):

Michael B. Mukasey, S.D.N.Y.

Preliminary Voir Dire (January 9, 1995) ................................................................ 353

Jury Questionnaire (January 9, 1995) ..................................................................... 361

v

Introduction

Assembled here are jury questionnaires used by federal judges in criminal prosecutions in national security cases. Also assembled here are prepared remarks for

prospective jurors in some of the cases. The materials are assembled in reverse

order of use. All but the questionnaire used in United States v. Sabir were used in

cases described in a companion publication, National Security Case Studies: Special Case-Management Challenges. Not all judges use jury questionnaires. The questions included here from United States v. Batiste were prepared by Judge Joan Lenard to ask potential jurors

orally, because she prefers face-to-face voir dire to jury questionnaires. Judge Kevin Duffy, who presided over United States v. Salameh, also believes that jury

questionnaires are not useful.

These and other resources potentially helpful to judges presiding over national 

security cases are assembled at the following FJC Online site: http://cwn.fjc.dcn/

fjconline/home.nsf/pages/1227. The materials collected here have been reformatted and copyedited.

United States v. Ghailani: 

Preliminary Remarks to Venire 

Hon. Lewis A. Kaplan 

Southern District of New York 

September 23, 2010 

The following text was prepared by U.S. District Judge Lewis A. Kaplan of the 

Southern District of New York to address prospective jurors selected for the 

prosecution of Ahmed Khalfan Ghailani for participation in the 1998 bombings 

of the American embassy in Dar es Salaam, Tanzania, United States v. Ghailani, 

No. 1:98-cr-1023-9 (S.D.N.Y. Sept. 21, 1998). Ghailani was a fugitive until 

2004, when he was captured and held by the CIA. He was transferred to Guantánamo Bay in 2006 and to the Southern District of New York for prosecution in 

2009. 

Preliminary Remarks to Venire 

Good morning, everybody. I’m Judge Lewis Kaplan. We are about to begin the 

process of selecting a jury for a criminal case, and I’m going to describe the 

process to you briefly and tell you just a little about the case. The process is a 

little different from the one we normally use. 

The first step in the process is going to occur today, this morning. In a few 

minutes, after you’ve been sworn, you’re going to be given questionnaires to fill 

out. It’s important that you be truthful and accurate in answering the questions on 

the questionnaires, because they’re going to be important in selecting the jury. 

When you’re done, the questionnaires will be collected, and you will be done for 

the day. You can go home. 

Some of you are going to be asked to return for the second phase of jury selection which will involve oral questioning that many of you are probably familiar with. That’s going to start on September 29. It may continue on the 30th and 

possibly for another day or so. Later today you’ll get instructions about how 

you’re going to find out whether you’re going to need to come back for oral 

questioning and exactly on which date and at what time you should come. 

Once the second phase, the oral questioning, is completed, a number of you 

will be asked to return for the final step in jury selection and some of those who 

will come back at the third phase will be selected to serve on the jury. We’re not 

a hundred percent certain of the date, but it’s very likely to be Monday, October 

4th. 

Now, the second thing I need to do is to tell you a little bit about this case. As 

I said to you at the outset, this is a criminal case. It’s brought by the United 

States. The defendant is a man named Ahmed Khalfan Ghailani. Mr. Ghailani is 

charged with various crimes arising out of the bombing of the United States embassies in Africa a number of years ago. Mr. Ghailani denies the charges against 

him. As in all criminal cases, he is presumed innocent and that presumption stays 

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United States v. Ghailani: Preliminary Remarks to Venire 

with him throughout the case, unless and until the government proves that he is 

guilty beyond a reasonable doubt. He doesn’t have to prove that he’s innocent. 

It is quite likely there is going to be press coverage in this case. There has 

been some already. I instruct you that you are not to read, watch, or listen to anything having to do with this case from this moment onward. You are not to discuss it among yourselves. You’re not to discuss it with family, friends, or anyone 

else. You’re not to do any research about the case or about anybody who is involved in it. That includes Google; it includes internet searches. No Googling, no 

Tweeting, none of that stuff. 

Finally, I’d like to explain to you that your privacy can and will be protected, 

even in a case in which there will be publicity, which is quite likely here. Some 

of you may have heard about jurors being sequestered, especially in the old days 

when people got called for jury duty and wound up on a case: they got sent to 

hotels with guards every night until the case was over. We don’t intend to do 

that. That’s mainly a historical artifact. Those of you who serve on the jury in 

this case will go home every night. However, the names and addresses and other 

identifying information about jurors, including their places of employment, will 

not be disclosed to anyone except the chief jury clerk who will send each juror 

his or her check for serving. This is to insure the privacy of the jurors, to make 

sure it’s preserved and to make sure that they are not contacted by the press or 

anybody else who may want to discuss the case with them. 

Now, as you’re going to learn in a few minutes, the questionnaires that you 

fill out will not have your names on them. Each of you has a number assigned to 

you and that number will go on the questionnaire. You’ll put it on there instead 

of writing your name. The names of the jurors in this case will not be known to 

the lawyers, the witnesses, or the parties, or even to me. Selecting an anonymous 

jury like this is not unusual. It’s been done in many cases in federal courts. Anonymity deters curiosity and protects the privacy of those selected to serve on the 

jury. In addition, once the jury is picked for this case, the jurors will be picked up 

every morning by deputy United States marshals at one or more convenient meeting places around the city, or possibly even outside the city, and driven from 

those pickup points right into the courthouse. 

While the jurors are in the courthouse, they’ll remain with the marshals. 

They’ll have their coffee breaks and their meals together. The Court will provide 

a light breakfast, coffee, other refreshments, and lunch every day; I guess I 

should say, at no charge. I think that’s right. I’m sure. In the evening the jurors 

will be driven from the courthouse by the marshals to one or more convenient 

dropoff points from which the jurors will then make their own ways home. The 

locations of the morning pickup places and the evening dropoff places will not be 

disclosed publicly. They’re likely to change during the course of the trial. 

And so that’s the way this is going to unfold. Three phases of jury selection; 

and for those persons who are ultimately selected, their privacy will be retained 

and they will be anonymous to the outside world and indeed even to court personnel except for one person who will keep juror identity information in a vault. 

So that’s my little story for you this morning. You’ll get the questionnaires in 

a few minutes. Most of you I will never see again, but I thank you in advance for 

your help and cooperation. I’m sure that down the road I will see some of you 

2 

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United States v. Ghailani: Preliminary Remarks to Venire 

once more at least. So be well and thanks again. And if there are any members of 

the press in here? No? Good. Okay. Thank you. 

3 

3
1 

United States v. Ghailani:

Jury Questionnaire

Hon. Lewis A. Kaplan

Southern District of New York

September 22, 2010

The following questionnaire was prepared by the Southern District of New 

York s United States District Judge Lewis A. Kaplan to facilitate jury selection 

in a prosecution for participation in the 1998 bombings of the American embassy 

in Dar es Salaam, Tanzania, United States v. Ghailani, No. 1:98-cr-1023-9 

(S.D.N.Y. Sept. 21, 1998). The defendant was a fugitive until 2004, when he was 

captured and held by the CIA. He was transferred to Guantánamo Bay in 2006 

and to the Southern District of New York for prosecution in 2009.

Background Information

This questionnaire is being used to assist in selecting a jury for what is expected 

to be a long trial.

The trial is expected to last 10 to 16 weeks or perhaps somewhat longer.

In general, the trial will be held Monday through Thursday, 9:30 a.m. until 

4:30 p.m., although there will be some shorter work weeks and the hours and 

days may vary from time to time.

Court will not be held during the following breaks and holidays:

October 11, 2010 

(Columbus Day) 

December 23, 2010, to 

January 3, 2011

November 2, 2010 

(Election Day)

January 17, 2011 (Martin

Luther King Day)

November 11, 2010 

(Veterans Day)

February 21, 2011 

(Presidents Day)

November 24 26, 2010 

(Thanksgiving)

February 28 to March 4, 

2011

Please answer each part of the following questions Yes or No and provide 

the additional requested information for all parts to which you answer Yes. If 

you need additional space, use the back of the page.

Write your juror number on every page in the space provided.

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United States v. Ghailani: Jury Questionnaire Juror No. __________ 2 

1. Would serving on this jury cause undue hardship or extreme inconvenience 

because

a. You would have to travel a great distance to the courthouse? If so, how 

many miles would you have to travel? Yes _____ If yes, number of miles _____ No _____

b. Your travel time to and from the courthouse would be excessive? If so, 

how many minutes are required (one-way)? Yes _____ If yes, number of miles _____ No _____

c. There is a grave illness in the family or other emergency? Yes _____ Explain. ________________________________________ _______________________________________________ _______________________________________________ No _____

d. Service would cause you undue hardship or extreme inconvenience for 

some other reason? Yes _____ Explain. ________________________________________ _______________________________________________ _______________________________________________ No _____

e. Service would cause severe economic hardship to your employer? Yes _____ Explain. ________________________________________ _______________________________________________ _______________________________________________ No _____

2. Does the nature of the charges cause you to believe that you could not serve 

impartially as a juror in this case? Yes _____ Explain. ___________________________________________ __________________________________________________ __________________________________________________ No _____

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United States v. Ghailani: Jury Questionnaire Juror No. __________ 3 

3. Does the allegation that the 1998 plot that destroyed the U.S. embassies in 

Africa was associated with al-Qaeda cause you to believe that you could not 

serve impartially as a juror in this case? Yes _____ Explain. ___________________________________________ __________________________________________________ __________________________________________________ No _____

4. The terrorist attacks on the United States, including on the World Trade Center, that occurred on September 11, 2001, are not at issue in this case. Nevertheless, have you had any personal experiences or do you have any feelings 

arising from those attacks that you believe would interfere with your ability 

to serve impartially as a juror in this case? Yes _____ Explain. ___________________________________________ __________________________________________________ __________________________________________________ No _____

5. Have you had any personal experiences or do you have any feelings arising 

from any other terrorist attacks on the United States or on anyone else that 

you believe would interfere with your ability to serve impartially as a juror in 

this case? Yes _____ Explain. ___________________________________________ __________________________________________________ __________________________________________________ No _____

6. On a scale of 1 to 5, how afraid are you that you, a family member, or someone close to you will be killed or injured in a terrorist attack? ( 1 = not 

afraid; 5 = very afraid) 

Select a number from 1 to 5 _____

7. Have you seen, heard, or read anything about Mr. Ghailani or the bombings 

of the U.S. embassies in Kenya and Tanzania in 1998? Yes _____ What? ____________________________________________ __________________________________________________ __________________________________________________ No _____

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United States v. Ghailani: Jury Questionnaire Juror No. __________ 4 

8. Do you have feelings about the prosecution of accused terrorists in courts 

like this that you believe would interfere with your ability to serve impartially as a juror in this case? Yes _____ No _____

9. Much of the conduct at issue in this case took place outside the United States, 

principally in Tanzania and Kenya. United States law provides that persons 

engaged in conduct occurring outside the United States may nevertheless be 

charged in United States courts for violations of federal laws that protect 

Americans abroad. Do you believe that conduct that takes place outside of 

the United States should not be a basis for American criminal charges or 

should not be considered by an American court? Yes _____ No _____

10. Have you, any family member, or any close friend been a victim of terrorism, 

either in this country or abroad? Yes _____ Explain. ___________________________________________ __________________________________________________ __________________________________________________ No _____

11. Do you have any feelings about Islam or Muslims that you believe would 

interfere with your ability to serve impartially as a juror in this case? Yes _____ Explain. ___________________________________________ __________________________________________________ __________________________________________________ No _____

12. Do you have any feelings about methods the United States has used in responding to terrorism including, for example, the use of military force or the 

detention of terror suspects by the CIA or by the Defense Department at 

Guantánamo Bay that you believe would interfere with your ability to serve 

impartially as a juror in this case? Yes _____ Explain. ___________________________________________ __________________________________________________ __________________________________________________ No _____

13. Do you have an opinion as to whether Mr. Ghailani is guilty or not guilty of 

any of the charges against him? Yes _____ No _____

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United States v. Ghailani: Jury Questionnaire Juror No. __________ 5 

14. The witnesses in this case will include law enforcement and perhaps other 

government personnel. Would you be more or less likely to believe such a 

witness solely by reason of the fact that the witness works in law enforcement or another government capacity? Yes _____ No _____

15. Do you have any biases or feelings for or against defendants in general, lawyers who represent persons accused of crimes, or prosecutors that you believe would interfere with your ability to serve impartially as a juror in this 

case? Yes _____ Explain. ___________________________________________ __________________________________________________ __________________________________________________ No _____

16. Have you, any member of your family, or any close friend ever been a victim 

of a crime? Yes _____ No _____ If yes, please describe. __________________________________________ _____________________________________________________________ If yes, do you believe that this would interfere with your ability to serve as an 

impartial juror in this case? Yes _____ No _____

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United States v. Ghailani: Jury Questionnaire Juror No. __________ 6 

17. Have you, or has any member of your family with whom you resided at the 

time, or a close friend, ever been employed by or received training from any 

local, state, or federal law enforcement agency, including but not limited to 

the following? (Circle as many as apply for each category.) Self Relative Close Friend

Federal Bureau of 

Investigation x x x 

U.S. Attorney x x x 

Bureau of Alcohol, Tobacco, 

Firearms & Explosives x x x 

U.S. Citizenship and 

Immigrations Services, and 

Bureau of Immigration and 

Customs Enforcement 

(formerly known as 

Immigration and 

Naturalization Services)

x x x 

Department of Homeland 

Security x x x 

Drug Enforcement 

Administration x x x 

Military Police x x x 

Department of Corrections x x x 

State Police x x x 

Office of District Attorney x x x 

United States Marshal Service x x x 

New York City Police 

Department x x x 

U.S. Bureau of Prisons x x x 

Department of Probation and 

Parole x x x 

Other: __________________ x x x 

If yes, do you believe this would interfere with your ability to serve as an 

impartial juror in this case? Yes _____ No _____

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United States v. Ghailani: Jury Questionnaire Juror No. __________ 7 

18. Have you or any close friend or relative, either as an individual or in the 

course of his or her business, ever been a party to any legal action or dispute 

with the United States or any of the officers, departments, agencies, or employees of the United States, or had any interest in any such legal action or 

dispute or its outcome? Yes _____ No _____

19. Have you, either through any experience you have had or anything you have 

seen or read, developed any bias or prejudice for or against the United States 

Attorney s Office, the Department of Justice, or the Federal Bureau of Investigation? Yes _____ No _____

20. Have you or any close friend or relative ever been involved or appeared as a 

witness in any investigation by a federal or state grand jury, a legislative 

committee, or any other governmental agency? Yes _____ No _____

21. Have you or any close friend or relative ever been a witness or a complainant 

in any hearing or trial? Yes _____ No _____

22. Are you or any close friend or relative now under subpoena or, to your knowledge, about to be subpoenaed in any criminal case? Yes _____ No _____

23. Have you or any close friend or relative ever been the subject of any investigation or accusation by any federal or state grand jury? Yes _____ No _____

24. Have you or any close friend or relative ever been charged with a crime? Yes _____ No _____

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United States v. Ghailani: Jury Questionnaire Juror No. __________ 8 

25. Have you or any member of your immediate family ever served in the military (including the National Guard and the reserves)? Yes _____ No _____ If yes, have you or any member of your family or close personal friend ever 

served in the Middle East, including Iraq and Afghanistan? Yes _____ No _____ If yes, describe the branch and the nature of the service and the approximate dates. _______________________________________________ _________________________________________________________ 26. Do you know anyone who now resides, or in the past resided in the Middle 

East, South Asia, including Pakistan and the areas around Pakistan, or sub- Sahara Africa? Yes _____ No _____

11
United States v. Ghailani: Jury Questionnaire Juror No. __________ 9 

27. Have you ever served as a juror?

Yes _____ No _____ If yes, please complete as appropriate:

a. Civil Cases Date(s) _______________________________ Nature of case(s): ___________________________________________ Federal or state case(s): ______________________________________ Was the jury asked to reach a verdict? Yes _____ No _____ If so, was a verdict reached? Yes _____ No _____

b. Criminal Cases Date(s) _______________________________ Nature of case(s): ___________________________________________ Federal or state case(s): ______________________________________ Was the jury asked to reach a verdict? Yes _____ No _____ If so, was a verdict reached? Yes _____ No _____

c. Grand Jury Date(s) _______________________________ Federal or state? ____________________________________________ 28. If you have served as a juror, was there anything about your jury experience 

that would make it difficult to serve fairly and impartially in this case? Yes _____ No _____

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United States v. Ghailani: Jury Questionnaire Juror No. __________ 10 

29. Have you worked in or traveled in Tanzania, Kenya, Saudi Arabia, Somalia, 

Sudan, Iraq, Pakistan, Afghanistan, or Egypt? Yes _____ No _____ If yes, please explain how long you were there and the reason for your 

visit(s). ______________________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 30. What are your primary sources of local and national news? _____________________________________________________________ _____________________________________________________________ 31. This questionnaire has tried to invite your attention to possible reasons why 

you might not be able to sit as a fair and impartial juror. Apart from anything 

you have disclosed above, is there any fact, circumstance, opinion, impression, attitude of mind, personal or other experience, or identification or 

membership with any group or organization that you believe would prevent 

you, if you are accepted as a juror in the trial of this case, from listening to 

the evidence with an open mind and deciding every issue fairly and impartially, solely upon the evidence and in accordance with the Courts instructions as to the law? Yes _____ No _____ If yes, please explain. ___________________________________________ _____________________________________________________________ _____________________________________________________________ 

13
1 

United States v. Shnewer: 

Jury Questionnaire

Hon. Robert B. Kugler

District of New Jersey

September 29, 2008

The following questionnaire was prepared by the District of New Jersey’s United 

States District Judge Robert B. Kugler to facilitate jury selection in a prosecution 

for planning to attack Fort Dix, United States v. Shnewer, No. 1:07-cr-459 

(D.N.J. June 5, 2007). Jury Questionnaire

As Judge Kugler explained to you, the purpose of this questionnaire is to provide 

guidance to the lawyers and the Judge and as a time-saving device. This is not a 

test of your knowledge of the laws of the United States. The rules of law that apply to this case will be explained by the Court to those persons who are actually 

selected as trial jurors.

Your questionnaire answers will be kept confidential, under seal by the 

court, and will not be made available to the public or the media. In fact, this 

case’s jury selection is anonymous, meaning that only the Judge and a few staff 

members working for the Court will know your name. Selecting an anonymous 

jury is not an unusual practice and has been done in many cases in federal court. 

Anonymity will ward off curiosity that may infringe on your privacy. Please 

write your juror number on each page of this questionnaire. Do not write 

your name on any part of this questionnaire, and please do not include any 

information that might reveal your identity such as your employer’s name 

or your address.

Please answer the questions as honestly and completely as possible. Remember, there are no “right” or “wrong” answers, only open and honest ones. In 

order for this process to work, it is important that you are completely candid regarding your actual views and opinions. Everyone involved in this process is relying on what you say. We are genuinely interested in what you think. It will not 

help if you give answers that are politically correct or that reflect what you think 

we want to hear or what a “good” juror would say. You are sworn to give truthful 

answers, and any deliberately false answer to any question could subject you to 

prosecution for perjury or false statements. We are relying on your honesty.

Please do not leave any question unanswered. If you do not understand a 

question, or do not know the answer, please write, “I do not understand,” or “I do 

not know.” If there are things you do not want to talk about in open court, please 

circle the question numbers and write “private” on the questionnaire.

If you require additional space for your responses or wish to make further 

comments regarding any of your answers, you may do so on the Explanation 

Sheet at the end of this questionnaire. Please indicate the number of the question 

that you are referring to on the Explanation Sheet before writing your response or 

comment.

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United States v. Shnewer: Jury Questionnaire 2 

Unless a question states otherwise, the fact that a particular question is asked 

does not imply that the subject matter of the question is an issue in the case. As 

you read the questions, you are not to draw any inferences about the issues that 

must be decided in this case.

You are instructed not to discuss this case or this questionnaire with 

anyone, including your family and fellow potential jurors.

Please print legibly and use only dark ink.

Please make sure that you sign the verification page at the end of this 

questionnaire.

15
United States v. Shnewer: Jury Questionnaire Juror No. __________ 3 

I. Background Questions

1. Where do you currently reside? City or Town: _______________ County: _______________

2. How long have you lived at your current address? Years: __________ Months: __________ If you have lived at your current address for less than two years, please indicate the city and state of your prior residence: _______________________ 3. What is your gender? Male _____ Female _____

4. What is your age? _____ years.

5. Do you have any difficulty reading, speaking, or understanding English? Yes _____ No _____ If yes, please specify: __________________________________________ ____________________________________________________________ ____________________________________________________________ 6. Where were you born? City and State: _______________ Country: _______________

7. What is your current marital status? Married _____ Partnered _____ Single _____ Widowed _____ Separated _____ Divorced _____ Never Married _____

8. Do you have any children, including step children and foster children? Yes _____ No _____ If yes, please state their genders and ages and, if applicable, their occupations. Do NOT state the name of any employer: ______________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

1616
United States v. Shnewer: Jury Questionnaire Juror No. __________ 4 

9. Do you have any grandchildren? Yes _____ No _____ If yes, please state their genders and ages and, if applicable, their occupations. Do NOT state the name of any employer: ______________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 10. Do you live with others? If so, provide the following information without 

stating any names: Relationship Sex Age Occupation/School Length of Time in Residence ____________________________________________________________ ____________________________________________________________

____________________________________________________________

____________________________________________________________

____________________________________________________________

____________________________________________________________ 11. Are you or your spouse or partner a naturalized U.S. citizen? Yes _____ No _____ If yes, please specify who, when citizenship was attained, and the country of 

origin: ______________________________________________________ ____________________________________________________________ ____________________________________________________________ 12. What do you regard as your ethnic and racial background and that of your 

spouse or partner? You: _______________________________________________________ Spouse/Partner (if applicable): ___________________________________ 13. What do you regard as your religion (if any) and that of your spouse or partner? If none, please write “none.” You: _______________________________________________________ Spouse/Partner (if applicable): ___________________________________ Do you still belong to the religion in which you were raised? Yes _____ No _____

14. Approximately how often do you attend religious services? ____________ 

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 5 

15. Are you employed?

Yes _____ No _____ If yes, please state the type of work that you do. Do NOT state the name of 

your employer: _______________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ How long have you been employed at your present job? _____ years. If yes, please state the most recent job you had before your current employment. Do NOT include the employer, but state the job title, type of work, 

and how long you held the job: ___________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________

If no, please state whether you are retired, between jobs, a homemaker, disabled, or a student, and the type of work that you most recently performed: ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 16. About how many employees work or worked at your present or most recent 

job? Under 10 _____ 100-200 _____ 10-50 _____ 200-500 _____ 50-100 _____ 500 or More _____

17. Do you or did you supervise other individuals? Yes _____ No _____ If yes, how many other individuals do you or did you supervise? ________ 

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 6 

18. If applicable, is your spouse or partner employed?

Yes _____ No _____ If yes, please state the type of work that your spouse or partner does. Do 

NOT state the name of your spouse or partner’s employer: _____________ ____________________________________________________________ How long has your spouse or partner been employed at his or her present 

job? _____ years. If no, please state whether your spouse or partner is retired, between jobs, a 

homemaker, disabled, or a student, and the type of work that he or she most 

recently performed: ____________________________________________ ____________________________________________________________ ____________________________________________________________ 19. If you are divorced, separated, or widowed, what was your spouse or partner’s employment? Do NOT name the employer: ____________________ ____________________________________________________________ 20. Please circle the highest grade that you completed in school: Grade: 1-8 9 10 11 12 College: 1 yr. 2 yrs. 3 yrs. 4 yrs. Vocational/Technical School: 1 yr. 2 yrs. 3 yrs. 4 yrs. Graduate/Professional School (specify): If you did not graduate from high school, did you obtain a G.E.D.? Yes _____ No _____ If you continued your studies beyond high school, what was your primary 

area of study and what degrees did you obtain? ______________________ ____________________________________________________________ 21. Do you have any physical or emotional problems or disabilities or are you 

taking any medications that might interfere with your ability to serve as a juror or may cause you difficulty in hearing, seeing, or understanding evidence in a trial? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________ 

19
United States v. Shnewer: Jury Questionnaire Juror No. __________ 7 

22. Do you have a prepaid vacation, a medical procedure for yourself or a close 

family member that cannot be rescheduled, or another commitment that may 

prevent you from serving as a juror in this case? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________ 23. This trial is expected to last approximately eight weeks. The trial will be 

conducted Monday through Thursday, from 9:30 a.m. to 4:30 p.m. Is there 

anything about these circumstances that will prevent you from serving as a 

juror in this case? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________ 24. During the trial, you will not be sequestered, meaning that you will not be 

required to remain overnight. Once your deliberations begin, however, you 

may be sequestered, meaning that you may stay in a hotel under Court supervision. The Court would bear the entire cost of this hotel stay and provide for your security. Is there anything about these circumstances that will 

prevent you from serving as a juror in this case? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________ II. Case-Specific Questions

25. The Government will be represented in this case by Assistant United States 

Attorneys William Fitzpatrick and Michael A. Hammer, Jr. Do you, anyone 

in your family, or a close friend know or have any connection to either of 

these people? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________ 

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 8 

26. The Government will be assisted in this case by F.B.I. Special Agent John J. 

Ryan and paralegal specialist Bethany R. Goldy, paralegal specialist Gail 

Horton, and IT specialist Jason DeJesus. Do you, anyone in your family, or 

a close friend know or have any connection to any of these people? Yes _____ No _____

27. Do you have any connection to anyone who is employed by an office of a 

United States Attorney; the United States Department of Justice; the Federal 

Bureau of Investigation; the Department of Homeland Security; Immigration and Customs; or Alcohol, Tobacco and Firearms? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________ 28. The defendants will be represented in this case by the attorneys listed below. 

Please indicate if you, anyone in your family, or a close friend know or have 

any connection to any of them.

Troy Archie, Camden, NJ

Rocco Cipparone, Jr., Haddon Heights, NJ

Michael Huff, Philadelphia, PA

Michael Riley, Mount Holly, NJ

Richard Sparaco, Cherry Hill, NJ Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________ 29. The defendants will be assisted by Giovanni Campbell, Esquire; Janelle 

Ryan-Colbert, Esquire; and Tracy Riley, Esquire. Please indicate if you, anyone in your family, or a close friend know or have any connection to any of 

them. Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________ 

21
United States v. Shnewer: Jury Questionnaire Juror No. __________ 9 

30. Please review this list of defendants and indicate if you, anyone in your family, or a close friend know or have any connection to any of them.

Mohamed Ibrahim Shnewer, Cherry Hill, NJ

Dritan Duka (also known as “Tony Duka”), Cherry Hill, NJ

Eljvir Duka (also known as “Sulayman”), Cherry Hill, NJ

Shain Duka (also known as “Shaheen”), Cherry Hill, NJ

Serdar Tatar, Philadelphia, PA Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________ 31. Have you seen, read, or heard anything about any of the defendants? This 

includes not only the media but anything you may have heard from friends, 

co-workers, family, or other people. Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________ 32. The potential witnesses in this case include the individuals listed below. 

Please indicate if you, anyone in your family, or a close friend know or have 

any connection to any of them.

Agron Abdullahu

Hekuran Abdullahu

Patricia Alber

William Alber

David Allen Ahmed Almghti

Mohamad Al-Mufti

Adrian Ambari

Robert Antoon Arabic Language Linguist, Federal Bureau of Investigation

Evan Arno Investigative Specialist, Federal Bureau of Investigation

John Augustine Special Agent, Federal Bureau of Investigation

Colonel Blan R. Ayyar United States Air Force

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 10

Besnik Bakalli

Bryan Baker Investigative Specialist, Federal Bureau of Investigation

Steven C. Baker Special Agent

Anthony Barbadoro Investigative Operations Analyst, Federal Bureau of Investigation

Robert Barbieri Special Agent

Joseph Barrios Task Force Officer

Captain Phillip Beachy United States Navy

Christopher Benson Investigative Specialist, Federal Bureau of Investigation

Scott Birkland Special Agent, Federal Bureau of Investigation

Emilio F. Blasse Special Agent

David F. Bole Special Agent

Casey Booth

Derek D. Boucher Special Agent

Lieutenant T. Bowns Federal Detention Center

Sean Brennan Task Force Officer, Federal Bureau of Investigation; Detective, Philadelphia Police Department

William P. Brooks, Jr. Special Agent

James Brosious Investigative Specialist, Federal Bureau of Investigation

Eric Brzowski Investigative Specialist, Federal Bureau of Investigation

Norman Burnosky Detective

Richard J. Cantirino Detective

James A. Carroll Task Force Officer

Robert S. Carroll Special Agent

Tina Marie Catrone

23
United States v. Shnewer: Jury Questionnaire Juror No. __________ 11

Colonel Stephen M. Christian United States Army

Alan Christie

Cheryl Christie

Mannzoor Chughti

Luke Church Special Agent

Warren Cline

Christopher Coomer Special Agent, Federal Bureau of Investigation

Officer D. Cunningham Federal Detention Center

Kimberly Cyganik Special Agent, Federal Bureau of Investigation

Lewis D. D’Agostino Detective Sergeant

James Dale

Sergeant Sean Dandridge Sergeant, Philadelphia Police Department

Denise Day Special Agent, Federal Bureau of Investigation

Joseph DeStefano

Peter M. DeStefano

Patricia Diaz Special Agent, Federal Bureau of Investigation

Benjamin Dugan

Burim Duka

Ferik Duka

Jennifer Duka

Ljavdrim Duka

Zurata Duka

Richard Dusak Forensic Handwriting Analyst, United States Secret Service

Ahmad A. Elfull

Salem Elkholy

John E. Ellis New Jersey State Police Investigator

Ahmad Elsull

2424
United States v. Shnewer: Jury Questionnaire Juror No. __________ 12

Issa Fakhoury Arabic Language Linguist, Federal Bureau of Investigation

Thomas Falletta Task Force Officer, Federal Bureau of Investigation; Detective 1, New Jersey State Police

Robert Fennimore

Fred Fife Task Force Officer

Grace Finmarro

Eugene Fletcher

Richard D. Foran Investigative Specialist, Federal Bureau of Investigation

John Franciotti Special Agent

Bastian Freund Special Agent

Ed Frimel Special Agent

Clement Fuscellaro Task Force Officer

Ed Gallant Special Agent

Mark Gillen Special Agent, Federal Bureau of Investigation

Mark Gillette

Ronald B. Good Special Agent

Heather C. Gonzalez

William Grace Special Agent, Federal Bureau of Investigation

William Grajewski Special Agent, Federal Bureau of Investigation

Jeffrey Gray Special Agent, Federal Bureau of Investigation

Ghassan M. Hajjar Arabic Language Linguist, Federal Bureau of Investigation

Jennifer Harlan

Robert Harlan

Colonel Steven B. Harrison United States Air Force

25
United States v. Shnewer: Jury Questionnaire Juror No. __________ 13

Mohamad B. Hasbull

Leah Haskel

Saida A. Hassan Special Agent

Kevin Hatton Special Agent, Federal Bureau of Investigation

Stephen J. Heaney Special Agent

Daniel Henkel Special Agent

Tracy L. Heylmann Special Agent

Leon Hinkle

Cynthia Horan

James Hunt Investigative Specialist, Federal Bureau of Investigation

Troy Hyman Task Force Officer 

Gregory Ilchenko

William Jezior Federal Detention Center

Michelle Johnston Investigative Specialist, Federal Bureau of Investigation

Hydeliza M. Jones

Linn Jones, Jr.

Victoria L. Jones Special Agent

Kevin Kane Supervisory Special Agent, Federal Bureau of Investigation

Mary Beth Kelly Investigative Specialist, Federal Bureau of Investigation

Walter Kerr Computer Forensic Examiner

Namiu Khan

Louis Kinkle Task Force Officer, Federal Bureau of Investigation; Sergeant, New Jersey State Police

Evan Kohlmann 

Alexis Krieger Investigative Specialist, Federal Bureau of Investigation

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 14

Michael Krupa

Katie L. Kurylo

Fred Lang Task Force Officer, Federal Bureau of Investigation; Senior Investigator, Camden County Prosecutor’s Office

Eugene Lanzillo Special Agent

Meredith Leap Investigative Specialist, Federal Bureau of Investigation

Mark Leason

Michelle Leason

John Leonard Special Agent, Bureau of Alcohol, Tobacco, Firearms, and Explosives

Mark Leone Investigative Specialist, Federal Bureau of Investigation

Key Lewis

Roberta Lorenzetti Supervisory Investigative Specialist, Federal Bureau of Investigation

Christopher S. Machovina Special Agent

Richard Macko Special Agent, Federal Bureau of Investigation

Pamela A. May

James McDonald Supervisory Special Agent, Computer Forensic Examiner, Federal Bureau of Investigation

Ryan McPeak Investigative Specialist, Federal Bureau of Investigation

George McGuire Computer Forensic Examiner

Steven Meagher Investigative Specialist, Federal Bureau of Investigation

Anderson Messer Supervisory Special Agent, Federal Bureau of Investigation

27
United States v. Shnewer: Jury Questionnaire Juror No. __________ 15

Kevin Mimm Special Agent, Federal Bureau of Investigation (retired)

Anvar Mirzayev

Khalida Mirzayev 

Musa Mirzayev

Stephen Mooney Investigative Specialist, Federal Bureau of Investigation

James Mordecai Special Agent

Brian Morganstern

Todd A. Murborn

Kenson Napoleon

Thomas Newsome Special Agent

Tim O’Brian Task Force Officer

Jacob W. O’Connell Special Agent

Mark Olexa Special Agent, Immigration Customs and Enforcement

Mahmoud Omar

Karen Pabon Special Agent

Bennezir Pacha

Sayd Noorahmad Pacha

Monica L. Palase

Edith Palconit

James Paoli

Michael Parmigiana Special Agent, Federal Bureau of Investigation

Jennifer Perusi Investigative Specialist, Federal Bureau of Investigation

Tony Phillips a/k/a/ Abdur Raheem

Robert Piecheck

Donald “Justin” Price Computer Forensic Examiner

Michael T. Poulton Special Agent

Burhan U. Rahman

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 16

Robert Rakitias Special Agent, Federal Bureau of Investigation

Lina M. Ramirez Special Agent

Edwin Ramos Task Force Officer

Joshua Reed Special Agent, Federal Bureau of Investigation

Kelly Richards Investigative Specialist, Federal Bureau of Investigation

Geraldine K. Richardson Deputy Chief Counsel, Immigration and Customs Enforcement

Andrew Rixham Special Agent, Federal Bureau of Investigation

Stefanie Roddy Special Agent

Vito Roselli Special Agent

Steven Russell Special Agent, Federal Bureau of Investigation

John Ryan Special Agent, Federal Bureau of Investigation

Jay Rycek Task Force Officer, Federal Bureau of Investigation; Detective, Philadelphia Police Department

Raiyan Syed

Naima Sabour

Jeffrey M. Sage

Edward Saks Special Agent, Federal Bureau of Investigation

Shiraz Saleem

Salem Management Company

Scott Schillinger Computer Forensic Examiner

Captain David L. Scott United States Coast Guard

Kevin Shanley Special Agent, Federal Bureau of Investigation

29
United States v. Shnewer: Jury Questionnaire Juror No. __________ 17

Hassan Sharamarke

Faten Shnewer

Hana Shnewer

Ibrahim Shnewer

Inas Shnewer

Salem Shnewer

Nouman Shubbar Task Force Officer

Daina Sileey

William Sinopole Special Agent, Federal Bureau of Investigation

Adnan Smailji

Irfran Smailji

Ismet Smailji

Muarem Smaili

Mumin Smaili

Ervin Smith III Investigative Specialist, Federal Bureau of Investigation

James Smith Special Agent, Federal Bureau of Investigation (retired)

Susanne Stavast

Mark Steele

John Stermel Task Force Officer, Federal Bureau of Investigation; Officer, Delaware River Port Authority

Teresa Stokes

Lindsey Stott Special Agent, Federal Bureau of Investigation (retired)

Brian Struzik Investigative Specialist, Federal Bureau of Investigation

Robert J. Sweeney Special Agent

Raiyan Syed

Bujar Taraku Albanian Language Linguist, Federal Bureau of Investigation

Katrina A. Tenor

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 18

Colonel Ronald R. Thaxton United States Army

Aaron Lee Thornock United States Navy

Louisa Tilsner

Thomas Tilsner

Ibraham Torkey

Sharon Torkey

Peter Trucksis Special Agent

Ilmi Tullari

Thomas Turley Task Force Officer, Federal Bureau of Investigation; Investigator, New Jersey Department of Homeland Security and Preparedness

Bernadette Turner Special Agent, Federal Bureau of Investigation

Richard Vasquez Firearms Enforcement Officer, Bureau of Alcohol, Tobacco, Firearms, and Explosives

Virginia Viola Investigative Specialist, Federal Bureau of Investigation

Ryan Velekei Investigative Specialist, Federal Bureau of Investigation

Steven Vosbikian

Iman Wahid

Ron Walk Task Force Officer

Marcia Weisenfeld 

Patrick White Special Agent, Federal Bureau of Investigation

Joseph Wright, Jr.

Sean Wright Investigative Specialist, Federal Bureau of Investigation

31
United States v. Shnewer: Jury Questionnaire Juror No. __________ 19

Hussein Yilmaz

Serpil Yilmaz

Mera Ziegler

Robert Zisel Sergeant Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________ 33. Have you seen, read, or heard anything about any of these witnesses? This 

includes not only through the media but anything you may have heard from 

friends, co-workers, family, or other people. Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 34. The judge who will preside over this case is the Honorable Robert B. Kugler. Do you, anyone in your family, or a close friend know or have any connection to Judge Kugler or a member of his staff? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 20

35. You are being considered for service as a juror in United States v. Mohamad 

Shnewer et al. The defendants are charged with conspiracy and attempting 

to murder members of the United States Armed Forces at Fort Dix, New 

Jersey, and elsewhere. The case has been discussed in the media as the “Fort 

Dix Six.” Have you read, seen, or heard anything about this case or the defendants? Yes _____ No _____ If yes, please state in detail everything you recall about this case or the defendants from reading, hearing, or seeing anything in the media or from any 

other source: _________________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________

____________________________________________________________ Did you read about it in a newspaper? Yes _____ No _____ Have you seen anything about it on TV or heard about it on the radio? Yes _____ No _____

Have you talked with anyone or overheard anyone—including family members, friends, neighbors, people at work, or others—talking about this case 

or the defendants? Yes _____ No _____ If yes, in general, what was discussed? _____________________________ ____________________________________________________________ ____________________________________________________________ Have you read about this case on the Internet, including any blog postings or 

comments to news articles? Yes _____ No _____ Have you posted any comments about this case on the Internet, including to 

blogs? Yes _____ No _____ If yes, what did you say? ________________________________________ ____________________________________________________________ ____________________________________________________________ 

33
United States v. Shnewer: Jury Questionnaire Juror No. __________ 21 Do you have any information about this case or these defendants from any 

other source?

Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________ 36. Based on everything you have read, seen, or heard about this case, do you 

have an opinion about the guilt or innocence of any of the defendants? Yes _____ No _____ If yes, what is your opinion? _____________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 37. Do you, anyone in your family, or a close friend have a connection to any of 

the following: United States Army Base at Fort Dix, located in Burlington 

County, New Jersey; McGuire Air Force Base, located in Burlington County, New Jersey; Lakehurst Naval Air Station, located in Ocean County, New 

Jersey; United States Army Base at Fort Monmouth, located in Monmouth 

County, New Jersey; Dover Air Force Base, located in Kent County, Delaware; United States Coast Guard Base, Sector Delaware Bay, located in 

Philadelphia, Pennsylvania; and the Greene Federal Building, located in 

Philadelphia, Pennsylvania? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 38. Did you, anyone in your family, or a close friend attend the 2006 Army- Navy football game? Yes _____ No _____

III. General Criminal Trial Questions

39. Under our United States Constitution, the defendants are presumed to be 

innocent and cannot be found guilty of any offense unless and until the 

United States has proved each element of that offense beyond a reasonable 

doubt. Do you accept this principle and agree to apply it? Yes _____ No _____

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 22

40. The defendants are not required to testify or to present their side of the story 

to the jury at all. Under our United States Constitution, the defendants have 

the absolute right to remain silent; and the jury may not consider the fact 

that the defendants choose not to testify as evidence against them. Do you 

understand that the defendants’ silence may not be held against them, and 

that you may not consider it in your deliberations? Yes _____ No _____

41. Do you think a defendant has an obligation or duty to explain his or her side 

of the case? Yes _____ No _____

42. If a defendant chooses to not testify, would you consider that to be evidence 

of that defendant’s guilt? Yes _____ No _____

43. Do you believe that if the United States brings a person to trial, that person 

is probably guilty? Yes _____ No _____ Unsure _____

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

did not commit? Yes _____ No _____ Unsure _____

45. Do you feel that because of your attitudes about, or experiences with, law 

enforcement officers, the testimony of a law enforcement officer is entitled 

to greater, or less, weight than a regular citizen witness simply because of 

his or her status as a law enforcement officer? Yes _____ No _____

46. At the conclusion of the case, the Court will instruct you on the law and explain to you the elements of the crimes charged in the indictment. Do you 

have any 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 _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

35
United States v. Shnewer: Jury Questionnaire Juror No. __________ 23

47. Do you believe that the protections of free speech in the United States extend to both citizens and noncitizens? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 48. Do you think a person can criticize the U.S. government and still be patriotic? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 49. Some of the defendants are citizens of the United States and some are not. 

Would you afford each of the defendants the same consideration? Yes _____ No _____

50. There will 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.” Before received in evidence, the court will 

have ruled that this evidence is lawfully before you and you may give it the 

weight you deem appropriate. How do you feel about electronic surveillance 

of private conversations? _______________________________________ ____________________________________________________________ 51. 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 some of the defendants. How do you feel 

about surveillance or searches of private property? ___________________ ____________________________________________________________ 

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 24

52. You may hear testimony in this case concerning the use of informants or 

cooperating witnesses by federal authorities in their investigation. One or 

more of these individuals may be called to testify in this case. Do you have 

any feelings about the United States using such informants or cooperating 

witnesses? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 53. You may hear testimony in this case concerning the use of American or foreign intelligence services. Do you have any feelings about American or foreign intelligence services? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 54. You may notice a security presence in the courthouse and the courtroom 

throughout this trial. Is there anything about this security presence that will 

affect your ability to sit as a juror in this case? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ Do you have any concerns about the security presence? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

37
United States v. Shnewer: Jury Questionnaire Juror No. __________ 25

IV. Knowledge of Arabic, Islam, Ethnicity, and Immigration

55. Do you speak, read, write, or understand the Arabic language or any dialect 

of Arabic? Yes _____ No _____ If yes, please indicate your proficiency (beginning, intermediate, conversational, or fluent) as to speaking, reading, writing, and understanding: _____ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 56. Do you read any Arabic-language newspapers or publications, watch any 

Arabic-language television programs, or view any Arabic-language Internet 

sites? Yes _____ No _____ If yes, please describe: _________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 57. Do you speak, read, write, or understand the Albanian language or any dialect of Albanian? Yes _____ No _____ If yes, please indicate your proficiency (beginning, intermediate, conversational, or fluent) as to speaking, reading, writing, and understanding: _____ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 58. Do you read any Albanian-language newspapers or publications, watch any 

Albanian-language television programs, or view any Albanian-language Internet sites? Yes _____ No _____ If yes, please describe: _________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 26

59. To the best of your knowledge, in what contexts have you had contact with 

people who follow the religion of Islam (Muslims) or are of Albanian, Jordanian, Turkish, or Palestinian descent? Please check all of the following 

answers that apply:

In the family _____ In the neighborhood _____ In organizations _____

Through work/business _____ In places of worship _____

In school _____ In everyday life (shopping, movies, etc.) _____

None _____ Other _____

60. In private matters, what words do you use to describe someone who practices the Islamic faith? ___________________________________________ 61. Is there anything about a case where a defendant or witness is Muslim 

(meaning that he or she practices the Islamic faith) that would make it difficult for you to serve as a fair and impartial juror? Yes _____ No _____ If yes, please describe: _________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 62. Do you personally know anyone who is a student of, or who practices, the 

Islamic faith? Yes _____ No _____ If yes, please describe your relationship to that person and whether you have 

discussed that person’s faith with him or her: ________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 63. How knowledgeable are you about the history and practices of the Islamic 

faith? Very knowledgeable _____ Somewhat knowledgeable _____ Slightly knowledgeable _____ Not knowledgeable at all _____

64. Do you believe that Islam endorses violence? Yes _____ No _____

39
United States v. Shnewer: Jury Questionnaire Juror No. __________ 27

65. Have you ever visited a mosque? Yes _____ No _____

66. Is there anything about Islamic teachings or doctrine that is offensive to

you? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 67. If you were to hear that one or more of the defendants have expressed negative views of Jewish people, would you hold it against the defendant? Yes _____ No _____

68. If you hear an allegation that any one of the defendants supported or sympathized with Osama bin Laden, al Qaeda, or the Taliban, would you be biased 

for or against that particular defendant? Yes _____ No _____

69. If you hear an allegation that any one of the defendants possessed and 

viewed jihadist videos, would you be biased for or against that particular defendant? Yes _____ No _____

70. Who do you think is responsible for the attack on the United States on September 11, 2001? ______________________________________________ 71. Are you familiar with the organization known as “al Qaeda”? Yes _____ No _____ If yes, please explain your understanding of what “al Qaeda” is: ________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 72. Do you have an opinion about the words “jihad” or “violent jihad”? Yes _____ No _____ If yes, please explain what you understand those words to mean: ________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 28

73. Do you have an opinion about the word “mujahideen”? Yes _____ No _____ If yes, please explain what you understand that word to mean: __________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 74. Do you have an opinion about the word “fatwa”? Yes _____ No _____ If yes, please explain what you understand that word to mean: __________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 75. Do you have an opinion about the word “Islamic” or “radical Islamic fundamentalists”? Yes _____ No _____ If yes, please explain what you understand those words to mean: ________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 76. Are you a member of or have you ever contributed money or gifts to an organization that takes a position on Islam or Muslims? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 77. If you hear the defendants encourage financial support of or to an organization of any pro-Islamic Muslim organization, would you be biased for or 

against that particular defendant? _________________________________ 

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 29

78. Are any of your relatives, close friends, or co-workers of Albanian, Turkish, 

Jordanian, or Palestinian descent? Yes _____ No _____ If yes, please describe: _________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 79. The defendants in this case are of Albanian, Turkish, Jordanian, and Palestinian descent. Do you have any negative feelings or opinions about Muslims or people who are of Albanian, Jordanian, Turkish, or Palestinian descent? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 80. Are you a member of or have you ever contributed money or gifts to an organization dealing with immigration? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 81. How do you feel about immigration reform? ________________________ ____________________________________________________________ 82. Do you have any positive or negative feelings about someone entering the 

United States illegally? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 30

83. Do you have strong feelings pertaining to issues concerning immigration? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ V. Military and National Security

84. Have you or any member of your immediate family ever served in the military, including the National Guard and military reserves? Yes _____ No _____ If yes, please describe the nature of such service, including the dates of service, branch of the military, rank, and duties: ________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ a. Have you or any member of your immediate family ever been involved 

in a court martial? Yes _____ No _____ If yes, please explain: ______________________________________ ________________________________________________________ ________________________________________________________

________________________________________________________ b. Have you or any member of your immediate family ever been involved 

in a combat situation? Yes _____ No _____ If yes, please explain: ______________________________________ ________________________________________________________ ________________________________________________________

________________________________________________________ 

43
United States v. Shnewer: Jury Questionnaire Juror No. __________ 31

85. Have you or anyone you know ever been stationed as a member of the 

armed forces or employed as a civilian at any of the following: United States 

Army Base at Fort Dix, located in Burlington County, New Jersey; McGuire 

Air Force Base, located in Burlington County, New Jersey; Lakehurst Naval 

Air Station, located in Ocean County, New Jersey; United States Army Base 

at Fort Monmouth, located in Monmouth County, New Jersey; Dover Air 

Force Base, located in Kent County, Delaware; United States Coast Guard 

Base, Sector Delaware Bay, located in Philadelphia, Pennsylvania; and the 

Greene Federal Building, located in Philadelphia, Pennsylvania? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 86. Have you or anyone you know served in a combat situation in Afghanistan, 

Iraq, or elsewhere in the Middle East? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________

If yes, does this affect your perception of Muslims? If so, please explain: _ ____________________________________________________________

____________________________________________________________

____________________________________________________________ 87. Do you know anyone who was a victim of a terrorist act, either in this country or abroad? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

4444
United States v. Shnewer: Jury Questionnaire Juror No. __________ 32

VI. Law, Government, and Law Enforcement

88. Have you ever served as juror? Yes _____ No _____ If yes, please state the date, court, nature of the case, whether there was a 

verdict, and what the verdict was: _________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________

If yes, did you serve as a foreperson or spokesperson? Yes _____ No _____

89. Have you ever served as a grand juror? Yes _____ No _____ If yes, did you serve as a foreperson or spokesperson? Yes _____ No _____

90. Have you or anyone in your family had any education or training in the law? Yes _____ No _____ If yes, please describe: _________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 91. Have you or anyone in your family ever worked in a law-related profession? Yes _____ No _____ If yes, please describe: _________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

45
United States v. Shnewer: Jury Questionnaire Juror No. __________ 33

92. Have you or anyone in your family ever worked in law enforcement in any 

capacity, including but not limited to as a police officer, sheriff’s officer, 

trooper, investigator, agent, corrections officer, or probation officer, or military police officer? Yes _____ No _____ If yes, please describe: _________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________

If no, have you, any relative, or close friend ever applied for a job in law 

enforcement or a criminal justice agency?: __________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 93. Have you or anyone in your family ever worked for another governmental 

agency? Yes _____ No _____ If yes, please describe: _________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 94. Do you or anyone in your house own any firearms? Yes _____ No _____ If yes, please describe: _________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 34

95. Do you have feelings pertaining to issues concerning firearms? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 96. Are you in favor of or opposed to gun control legislation? In favor _____ Opposed _____

97. Have you or anyone in your immediate family ever been charged with a 

crime? Yes _____ No _____ If yes, please describe: _________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ a. If you or anyone in your immediate family has ever been charged with 

a crime, do you feel that person was treated fairly by law enforcement 

and the criminal justice system? Yes _____ No _____ If no, please explain: _______________________________________ ________________________________________________________ ________________________________________________________

________________________________________________________ 98. Have you ever testified as a witness in a legal proceeding? Yes _____ No _____ If yes, please describe: _________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

47
United States v. Shnewer: Jury Questionnaire Juror No. __________ 35

99. Have you, a member of your family, or a close friend ever been the victim 

of a crime? Yes _____ No _____ If yes, please describe: _________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 100. To your knowledge, have you, a member of your family, or a close friend 

ever been the subject of a surveillance (visual, photographic, or electronic) 

by law enforcement? Yes _____ No _____ If yes, please describe: _________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 101. Have you or a member of your family ever been, or do you or they expect to 

become, involved in any legal action or dispute with the United States or 

any agency, officer, or employee of the United States, or have you ever had 

any financial interest in such a dispute? Yes _____ No _____ If yes, please describe: _________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 102. Have you or a member of your family ever been, or do you or they expect to 

become, involved in any legal action or dispute with any state, county, or 

local government or any agency, officer, or employee of any state, county, 

or local government, or have you ever had any financial interest in such a 

dispute? Yes _____ No _____ If yes, please describe: _________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 36

VII. Media and Hobbies

103. Please state the name of any newspapers, magazines, or other publications 

that you or your family have subscribed to in the past five years: ________ ____________________________________________________________ ____________________________________________________________ 104. Please state the name of any newspapers and magazines that you do not subscribe to but read regularly and state how often you read each publication: ____________________________________________________________ ____________________________________________________________ 105. Please state any television newscasts, including cable newscasts, that you 

watch regularly: ______________________________________________ ____________________________________________________________ ____________________________________________________________ 106. Please state any radio broadcasts, including talk radio, that you listen to regularly and indicate how often you listen to them: _____________________ ____________________________________________________________ ____________________________________________________________ 107. Please state any Internet sites, including social network sites and blogs, that 

you visit regularly: ____________________________________________ ____________________________________________________________ ____________________________________________________________ 108. Please list any hobbies or activities that you enjoy during any leisure time: ____________________________________________________________ ____________________________________________________________ 109. This case may receive media attention. The Court wants to make sure that 

this case is decided solely on the evidence presented in the courtroom and 

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

must avoid reading about the case in the newspapers or on the Internet, or 

listening to any radio or television reports about the case. You must avoid 

discussing this case with friends or family. Would these requirements pose 

any difficulty for you? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 37

VIII. Miscellaneous

110. Is there any other reason why you do not feel that you can serve as a fair and 

impartial juror in this case? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 111. As a result of having been asked to fill out this questionnaire, have you 

formed any opinions about this case? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 112. What was your reaction when you learned what case you had been called 

for? ________________________________________________________ ____________________________________________________________ 113. Do you want to be a juror in this case? Why or why not? ______________ ____________________________________________________________ ____________________________________________________________ 114. If you listed anything that would make it difficult or impossible for you to 

serve on a jury, what, if anything, could be done to make your serving easier 

or possible? __________________________________________________ ____________________________________________________________ ____________________________________________________________ 115. Do you have any religious, philosophical, moral, or other belief that might 

make you unable to render a verdict in a criminal case? Yes _____ No _____ If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ Please sign the verification on page 40.

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 38

EXPLANATION SHEET PAGE 1

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 39

EXPLANATION SHEET PAGE 2

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United States v. Shnewer: Jury Questionnaire Juror No. __________ 40

VERIFICATION SHEET

Please note that the jury clerk will detach this page from the questionnaire when 

you turn it in. No one else will see this page. I swear that the answers given by me to the questions on this Juror Questionnaire 

are truth to the same effect as if I were sworn under oath in open court to give 

truthful answers to the same. _____________________________________________ Signature

Name: _______________________________________ Address: _____________________________________ Phone Number: ________________________________ Juror No.: __________ Date: ______________ Please note that from this point on until you are dismissed from further service as a juror, you are under court order that prohibits you from reading about 

this case, watching or listening to any broadcasts about this case, doing any research on the Internet or elsewhere about this case, and discussing this case with 

anyone else. Thank you.

53
1 

United States v. Sadequee: 

Jury Questionnaire

Hon. William S. Duffey, Jr.

Northern District of Georgia

September 29, 2008

The following questionnaire was prepared by the Northern District of Georgia’s 

United States District Judge William S. Duffey, Jr., to facilitate jury selection in 

a terrorism prosecution, United States v. Sadequee, No. 1:06-cr-147 (N.D. Ga. Mar. 23, 2006). The questionnaire was prepared in collaboration with attorneys 

for both sides. After prospective jurors filled it out and before follow-up voir dire 

began, the defendant elected to represent himself.

The questionnaire is presented in two parts so that some questions are answered before prospective jurors know much about the case on which they may 

serve.

Jury Questionnaire Part 1 

You are part of the panel of prospective jurors for the above-listed case. To make 

the jury selection process more efficient and effective for everyone, you will be 

completing the following questionnaire. It is designed to elicit from you information that will assist the prosecution and the defense in making important decisions as to which of you will serve as jurors during the trial. Your answers will 

remain confidential and under seal; they will be used only by the Judge and the 

parties to select a qualified and impartial jury.

Do not discuss the questions or your answers with friends, family members, 

or fellow panelists. It is important that your answers are yours and yours alone. 

The questions are not meant to be intrusive, but you will be asked about some 

personal matters. Your answers will help the Judge, the Government, and the Defendant select the best jury possible in a way that respects your time and privacy. 

After a jury has been selected, all copies of your responses to this questionnaire 

will be returned to the Clerk of the Court and kept in confidence and under seal. 

The parties are under orders to maintain the confidentiality of any information 

they learn in the course of reviewing these questionnaires and discussing them 

with you.

Please write your juror number on every page in the blank provided.

Please print your answer to each question as legibly, completely, and accurately as you can. Please answer every question, and do not leave any question 

blank. If the question does not apply to you, write “N/A” for not applicable. If 

there is something you would like to discuss privately with the Judge and the 

lawyers, and not in front of the other jurors, please note this in your answer to the 

question or questions causing you concern.

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 2 

You must sign your questionnaire; your answers will be given the same effect as a statement given to the Court. What is needed is your very best, honest 

effort to answer all of the questions contained in this questionnaire. You should 

not disclose to anyone else the fact that you have been summoned for this case. 

You should avoid learning anything about the case through the media, on-line 

research, or otherwise between now and the conclusion of the jury selection 

process. You should not discuss this case, its subject matter, or this questionnaire 

with anyone, including those family members closest to you.

Thank you for your time and candor. 1. Name (first, middle, last): _______________________________________ 2. Maiden Name: ________________________________________________ 3. Gender: __________

4. Age: __________

5. City and County of Residence: ___________________________________ If Atlanta, list neighborhood or area: ______________________________ 6. How long have you lived at your current address?

7. List other cities in which you have lived during the past 10 years: 8. What is your ethnic background? _____ White/Caucasian, not Hispanic _____ Black/African-American, not Hispanic _____ Hispanic/Latino

_____ Asian or South Asian

_____ American Indian or Native American

_____ Other: ________________________________________________ (please specify)

9. City, state, and country of birth: __________________________________ If you were not born in the United States, when did you become a citizen? 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 3 

10. Are you able to read, write, and understand the English language without 

any difficulty?

Yes _____ No _____ If no, please explain: 11. Is English your first language?

Yes _____ No _____

12. What other languages do you speak, read, or understand? 13. What is your educational background? (Answer all that apply to you) _____ Grade school or less _____ Some high school _____ Technical or business school _____ Graduated from high school at _____________________________ _____ Some college at _________________________________________ _____ Graduated from college at _________________________________ with a degree in _________________________________________ _____ Completed graduate school at ______________________________ with a degree in _________________________________________ 14. Have you or any member of your immediate family had any legal training or 

studied law, including by participating in a paralegal program or through onthe-job training? (Note: For the purposes of this questionnaire, the term 

“immediate family” includes a spouse, domestic partner, father, mother, 

sister, brother, daughter, or son.)

Yes _____ No _____ If yes, please describe: 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 4 

15. Current (or most recent) employment status (check all that apply): _____ Self-employed

_____ Work full-time _____ Work part-time _____ Homemaker for _____ years _____ Student for _____ years; currently at ______________________________ (name of school) _____ Disabled and unable to work for _____ years _____ Unemployed/laid off for _____ years or _____ months _____ Retired for _____ years _____ Other: ________________________________________________ 16. Where do you work now? 17. Describe your current job and what you do: 18. List other jobs you have had in the past 10 years: 19. Have you ever owned or managed your own business?

Yes _____ No _____

20. Do you supervise others in your current job or in previous jobs?

Yes _____ No _____ If so, how many? _____

21. Are you: Single _____ Married _____ Domestic Partner _____ Separated _____ Divorced _____ Widowed _____

22. Your spouse or domestic partner’s name: ___________________________ 23. Your spouse or domestic partner’s city, state, and country of birth: 24. Your spouse or domestic partner’s current occupation: 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 5 

25. Your spouse or domestic partner’s occupations in the past 10 years: 26. Your spouse or domestic partner’s educational background: 27. If there are any additional adults living in your household, please tell us 

what type of work they do (or school they attend), and their relationship to 

you: 28. Do you have children?

Yes _____ No _____

If yes, how many? _____

29. If applicable, please complete the following for your children over 18 years 

old (for more than four children, provide the requested information on the 

back of this page):

a. First Child: Gender: _____ Age: _____ School Attending: _________________________________________ Current Employment: ______________________________________ b. Second Child: Gender: _____ Age: _____ School Attending: _________________________________________ Current Employment: ______________________________________ c. Third Child: Gender: _____ Age: _____ School Attending: _________________________________________ Current Employment: ______________________________________ d. Fourth Child: Gender: _____ Age: _____ School Attending: _________________________________________ Current Employment: ______________________________________ 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 6 

30. Have you served in the military?

Yes _____ No _____

a. If yes, which branch? ______________________________________ b. What were your dates of service? _____________________________ c. What was your rank at discharge? ____________________________ d. Were you honorably discharged? _____________________________ e. Were you ever deployed to a war or combat zone?

Yes _____ No _____ If yes, please describe where, when, and your role: 31. Has an immediate family member served in the military?

Yes _____ No _____ If yes, who? ________________________________ a. If yes, which branch? ______________________________________ b. What were their dates of service? _____________________________ c. What was their rank at discharge? ____________________________ d. Were they ever deployed to a war or combat zone?

Yes _____ No _____ If yes, please describe where, when, and their role: 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 7 

32. Have you or any members of your immediate family ever worked for a 

local, state, or federal government, including any law enforcement agency?

Yes _____ No _____

a. If yes, who? b. What was the job? c. Are you or your family members still working in this position, and, if 

not, when was the last time the person held this position? 33. Have you ever been involved in a lawsuit (other than a divorce case)?

Yes _____ No _____

a. How many lawsuits have you been involved in? b. Were you the plaintiff? c. Were you the defendant? d. What was the nature of the suit or suits? e. Were you satisfied with the results, and, if not, why? 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 8 

34. Have you ever served as a trial juror?

Yes _____ No _____

a. When? __________________________________________________ (If more than once, please provide the additional information on the 

back of this page.)

b. Was it criminal? _____ or civil? _____

c. Was it state? _____ or federal? _____

d. If criminal, what kind of case was it? e. Did you reach a verdict?

Yes _____ No _____

f. Were you the jury foreperson?

Yes _____ No _____

35. Have you served as a grand juror?

Yes _____ No _____

a. Was it state? _____ or federal? _____

b. Were you the grand jury foreperson?

Yes _____ No _____

36. Have you or an immediate family member ever worked for a lawyer or in a 

law office?

Yes _____ No _____ If yes, who did, and what were your or their responsibilities? 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 9 

37. Have you, an immediate family member, or a close friend ever been Yes, an immediate Yes, family member or I have a close friend has No

a. charged with a crime? _____ _____ _____

b. convicted of a crime? _____ _____ _____

c. incarcerated? _____ _____ _____

d. investigated by law _____ _____ _____

enforcement?

e. the victim of a crime? _____ _____ _____

f. unfairly treated by law _____ _____ _____

enforcement? If you answered yes to any of the above, please explain. 38. Have you, an immediate family member, or a close friend ever had a 

particularly good or bad experience with the following? (Please check all

that apply.) _____ Law enforcement (police officer, sheriff’s deputy, federal agent, etc.) _____ Prosecutor or prosecutor’s office _____ Criminal defense attorney or defense attorney’s office _____ Court or judge _____ Any federal, state, or local agency If yes, please explain the circumstances and state who was involved and 

whether it was a good or bad experience and why. 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 10

39. Do you believe that

a. racial minorities are treated differently by police and law enforcement?

Yes _____ No _____ If yes, please explain: b. religious minorities are treated differently by police and law 

enforcement?

Yes _____ No _____ If yes, please explain: c. ethnic minorities are treated differently by police and law enforcement?

Yes _____ No _____ If yes, please explain: 40. Are you aware of anyone who you feel was unfairly investigated or 

prosecuted for a crime?

Yes _____ No _____ If yes, please explain: 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 11

41. Are you, an immediate family member, or anyone close to you employed in, or do you have a background or training in, any of the following? (Please 

check all that apply.) _____ Law enforcement (including police, sheriff, FBI, or other federal agency) _____ United States Attorney’s office or other prosecutor’s office _____ Lawyer’s office _____ Local, state, or federal government _____ Court system

_____ Corrections (or prison system) _____ Any intelligence agency (such as the CIA, the National Security Agency, or any intelligence service of the military) If you checked any, please explain who and what office or agency: 42. Have you or any member of your immediate family ever had any legal

dispute or claim with or against any department or agency of any local, 

state, or federal government?

Yes _____ No _____

If yes, state briefly the nature of the dispute or claim and the resolution, if 

any: 43. Have you or anyone in your immediate family ever had assets seized or 

other collection measures (including garnished wages or a levy on bank 

accounts) initiated by any federal or state agency, including for child 

support payments?

Yes _____ No _____ If yes, please explain: 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 12

44. Have you ever been involved in a court proceeding in any other way?

Yes _____ No _____ If yes, please check all that apply: _____ A witness _____ Giving a deposition

_____ Other: ________________________________________________ (please explain)

45. Please list the newspapers, magazines, internet sites, and other news sources 

that you review on a regular basis: 46. How often do you or your spouse read newspaper editorials or opinion 

pages (including blogs and internet news sites)? _____ Daily

_____ Weekly

_____ Monthly

_____ I don’t follow the news

47. What types of books do you enjoy reading? 48. What programs and stations do you listen to on the radio? 49. What television shows do you enjoy? 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 13

50. Have you or your spouse ever written a letter to the editor of a newspaper,

called a radio or television station, or posted a comment on-line about an 

issue?

Yes _____ No _____ If yes, what was the issue? 51. Do you or your spouse frequently watch truTV (formerly Court TV) or 

crime shows such as CSI, Law and Order, or Nancy Grace?

Yes _____ No _____ If yes, which shows? 52. Do you follow major criminal trials in the news?

Yes _____ No _____ If yes, what trials have you followed or are you following? 53. What are your favorite leisure-time interests, hobbies, or activities? 54. Do you spend time solving crossword puzzles, jigsaw puzzles, or other types 

of puzzles?

Yes _____ No _____ If yes, do you consider yourself to be accomplished at this hobby? 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 14

55. Please list the last five movies you have seen in a theater or on tape, a DVD, 

or television: 56. Do you have a bumper sticker or a personalized license plate on your car?

Yes _____ No _____ If yes, what does it (they) say? 57. How often do you use the internet? 58. For what purposes do you use the internet? 59. Do you have your own social networking page (for example, a page on 

Facebook, MySpace, or Twitter)?

Yes _____ No _____ If yes, what website hosts your page? 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 15

60. Have you talked or do you talk on-line?

Yes _____ No _____

a. If yes, how? Chatrooms _____

Instant Messaging _____ Skype _____ Other (please specify): _____________________________________ b. If yes, how often? Daily _____ Weekly _____ Rarely _____

c. If you have children, do they communicate on line? 61. Are you familiar, through formal studies in school or otherwise, with any of 

the following:

The Occult Yes _____ No _____ The Kabbala Yes _____ No _____ Astrology Yes _____ No _____ Egyptian religions Yes _____ No _____ The New World Order Yes _____ No _____ The Anti Christ Yes _____ No _____ Please explain any yes answer: 62. Do you blog or write your thoughts or comments on-line?

Yes _____ No _____ If yes, on which websites have you blogged or posted thoughts or 

comments? 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 16

63. What is your religious affiliation, if any? 64. Are you a member of a church, mosque, synagogue, temple, or other 

religious institution?

Yes _____ No _____ If yes, please state any offices or leadership positions you hold or have held: If yes, how often do you attend? _____ every week

_____ occasionally

_____ only on significant religious holidays or occasions

65. Have you studied religion or comparative religion in school?

Yes _____ No _____ If yes, please explain what you have studied: 

66. Do you consider yourself to be politically _____ very liberal _____ somewhat liberal _____ moderate _____ somewhat conservative _____ very conservative _____ none of the above

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 17

67. Please list the names of all organizations to which you or your immediate 

family members belong, including clubs, unions, societies, fraternal 

organizations, and professional organizations, and state any offices you hold 

or have held in these organizations: 68. The Judge and the parties estimate this case may last up to two weeks. Do 

you have any _____ physical problems (such as an inability to remain seated for 2-3 

hours at a time) _____ medical problems (such as with your sight or hearing) _____ other conditions or issues ___ that would make it difficult for you to serve as a juror in this case? If so, please explain: 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 18

69. Jury service is one of the highest duties—and privileges—of being a United 

States citizen; your participation is essential to the proper administration of 

justice. Mere inconvenience or the usual financial and personal hardships of 

jury service will not excuse you from serving on this case. You must show 

that service in this case would cause an unacceptable hardship before you 

will be excused from jury duty. Would you have a serious hardship if chosen for this case? Yes _____ No _____ If yes, please fully explain your hardship and the arrangements you could 

make to alleviate your hardship: JUROR’S OATH I declare under penalty of perjury that the information that I have provided in this 

Juror Questionnaire is true and correct. _________________ _____________________________________ DATE JUROR SIGNATURE Printed Name: ____________________________________________________ Juror Number: __________ Jury Questionnaire Part 2

You are part of the panel of potential jurors for the case of United States v. Ehsanul Islam Sadequee. The United States is represented by Robert McBurney and 

Christopher Bly of the United States Attorney’s Office for the Northern District 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 19

of Georgia and Alexis Collins of the Counterterrorism Section of the United 

States Department of Justice. The Defendant is represented by Donald F. Samuel 

of Garland, Samuel & Loeb, P.C., and Khurrum Wahid of Wahid, Vizcaino & 

Maher, LLP.

Defendant Sadequee has been indicted by a federal grand jury and charged 

with conspiring to provide, attempting to provide, and providing material support 

and resources to terrorists and to a foreign terrorist organization.

An indictment is merely an accusation. It is not proof or evidence. You may 

draw no inference against the Defendant from the fact that he has been indicted. 

The Defendant has pleaded not guilty, and he is presumed innocent. The Defendant does not have to prove anything, and the Government bears the burden of 

proving the Defendant guilty beyond a reasonable doubt.

Please complete the remaining questions, which are specific to this case, just 

like you completed those in the first questionnaire. Thank you again for your 

time, honesty, and cooperation. 70. Do you know or have you had any contact (personal, business, or social) 

with _____ Judge William S. Duffey, Jr., or any member of his staff _____ Any other judge in the Northern District of Georgia _____ David E. Nahmias, the United States Attorney for the Northern District of Georgia _____ Robert McBurney, Alexis Collins, or Christopher Bly (the prosecutors) _____ Anyone else who works in the United States Attorney’s Office _____ Ehsanul Islam Sadequee (the defendant) _____ Anyone in Ehsanul Islam Sadequee’s family

_____ Donald F. Samuel or Khurrum Wahid (the defense attorneys) _____ Anyone who works in Donald Samuel’s firm (Garland, Samuel & Loeb) or anyone who works in Khurrum Wahid’s firm (Wahid, Vizcaino & Maher) _____ Any other person in the jury pool If yes, please list whom you know or have had contact with, and how you 

know that person: 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 20

71. Do you hold any belief, religious or otherwise, which discourages or 

prevents jury service? 72. Do you have any knowledge about the facts in this case or about Defendant 

Sadequee other than what you have learned today?

Yes _____ No _____ Not Sure _____ If yes or not sure, what knowledge do you have? 73. Do you know any other person who has been called to serve as a juror in this case? Yes _____ No _____ If so, how did you learn of their service? 74. Have you read, seen, or heard about this case in any newspaper, TV, or 

radio program, internet site, or any other source?

Yes _____ No _____ Not Sure _____ If yes or not sure, what have you read, seen, or heard? What stands out most in your mind about what you have read, seen, or 

heard? 

73
United States v. Sadequee: Jury Questionnaire Juror No. __________ 21

75. Have you formed any opinion about the case or about Defendant Sadequee? Yes _____ No _____ If yes, what is your opinion? 76. There was a trial earlier this summer involving an alleged co-conspirator of 

Defendant Sadequee’s whose name is Syed Haris Ahmed. What, if anything, 

do you know about that trial? 77. (Answer required only if you answered that you know something about the 

trial mentioned in Question 76.) If you have knowledge of the earlier trial of 

Syed Haris Ahmed, would that make it difficult for you to listen to the 

evidence with an open mind and render a verdict based solely on the 

evidence presented during this trial and the law as instructed by the Judge?

Yes _____ No _____ Not Sure _____ If yes or not sure, please explain: 78. Are you able to put aside any other pre-trial publicity or information that 

you have received regarding this case and focus only on the evidence that is 

presented in the trial and the legal instructions given to you by the Judge?

Yes _____ No _____ Not Sure _____ If no or not sure, please explain: 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 22

79. Before trial and as the trial proceeds, this case may be the subject of stories 

in the media. The Judge will instruct you not to read, browse, or listen to 

any of this media coverage. Please explain any concerns you have about 

following this instruction. 80. The Judge will also instruct you not to use the internet or any other sources 

to research anything about this case. Please explain any concerns you have 

about following this instruction. 81. Do you know, or have you read, seen, or heard anything about, the 

following people? (Please check all that apply) _____ Matthew Acker _____ Mariam Ahmed

_____ Syed Haris Ahmed

_____ Zubair Ahmed

_____ Hiam Akley

_____ Tim Alexandre _____ James Allen

_____ Mirsad Bektasevic _____ Aparna Bhattacharyya _____ Veera Boonyasait _____ Craig Bowling

_____ Anes Cengic _____ Michael Culkin

_____ Richard Dearsley

_____ Dr. Fawaz Gerges _____ Melissa Harper _____ Omer Kamal _____ Sheraz Khalid

_____ Aabid Hussein Khan

_____ Evan Kohlmann

_____ John Maguire _____ Finn Månsson

_____ George “Doug” McGee

75
United States v. Sadequee: Jury Questionnaire Juror No. __________ 23

_____ Lilima Nagpul _____ William Puller _____ Neil Rabinovitz _____ Mark Richards _____ Amimul Sadequee _____ Sharmin Sadequee _____ Sonali Sadequee _____ Michael Scherck

_____ Khaled Sediqi _____ Sardar Sharif _____ Younis Tsouli _____ T. Michael Williamson

_____ Kathy Wilz If so, please explain: 82. Some people believe that persons of certain ethnic, racial, or religious 

groups are more (or less) likely to commit crimes. What is your feeling 

about this? 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 24

83. With regard to the United States’ criminal justice system, do you think there 

is a difference between the way minority-group defendants, such as 

individuals of the Muslim faith or of South-Asian heritage, are treated as 

compared to non-minority defendants? (For this questionnaire, a person of 

“South-Asian heritage” means someone with family roots in India, Pakistan, 

Bangladesh, or Afghanistan.)

Yes _____ No _____ Not Sure _____ If yes or not sure, please explain: Would that belief make it difficult for you to consider the evidence in this 

case with an open mind and render a verdict based solely on the evidence 

and the legal instructions provided in Court? Yes _____ No _____

84. Have you ever met someone who is of the Muslim faith?

Yes _____ No _____ Not Sure _____

85. Have you, any immediate family member, or a close friend had any 

significant negative or positive experiences involving someone of the 

Muslim faith or South-Asian heritage in a personal, social, business, or other 

context?

Yes _____ No _____ Not Sure _____ If yes or not sure, please explain: Would such experience or experiences make it difficult for you to listen to 

the evidence in this case with an open mind and render a verdict based 

solely on the evidence and legal instructions presented in Court? Yes _____ No _____

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 25

86. Some people say that people accused of serious crimes are frequently treated 

too leniently by the courts, while others say they are treated too harshly.

What is your view? 87. Is there anything about the nature of the charges in this case or the defendant 

in this case that would cause you a problem in serving as a juror in this trial?

Yes _____ No _____ Not Sure _____ If yes or not sure, please explain: 88. Have you or any member of your immediate family experienced what you 

believe to be discrimination because of your race, ethnicity, or religion?

Yes _____ No _____ If yes, please explain: 

89. Do you think that your experiences with discrimination or your views on 

discrimination would affect your ability to be fair and impartial in this case?

Yes _____ No _____ Not Sure _____ If yes or not sure, please explain: 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 26

90. When you hear that someone is of the Muslim faith or South-Asian heritage, 

does that affect your perception of that person _____ in a positive way, _____ in a negative way, or _____ not in any way? Please explain: 91. Do you believe that the United States’ military should be present in the 

Middle East, Iraq, or Afghanistan?

Yes _____ No _____ Not Sure _____ Please explain: 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 27

92. Given that this case involves a defendant of Muslim faith and South-Asian 

heritage charged with terrorism-related crimes, do you have any feelings or 

impressions about _____ the United States’ government, _____ the United States’ military, _____ the United States Department of Justice, _____ the Federal Bureau of Investigation (FBI), _____ the Central Intelligence Agency (CIA), _____ the National Security Agency (NSA), or _____ any other governmental department or agency that would make it difficult for you to listen to the evidence with an open 

mind and render a verdict based solely on the evidence presented during 

trial and the law as instructed by the Judge?

Yes _____ No _____ Not Sure _____ If yes or not sure, please explain: 93. Do you think that someone who merely possesses written material that 

provides justifications for the killing of non-Muslims should be prosecuted 

for his possession of such materials?

Yes _____ No _____ Not Sure _____ If yes or not sure, please explain: 

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United States v. Sadequee: Jury Questionnaire Juror No. __________ 28

94. Do you think it should be a crime for someone to express his or her support 

for a terrorist organization, such as Al Qaeda?

Yes _____ No _____ Not Sure _____ Please explain: 95. Have you heard of the designated terrorist organizations Lashkar-e-Tayyiba 

(also known as “LET”) or Jaish-e-Mohammed (also known as “JEM”)? Yes _____ No _____ If yes, please explain what you know: 96. What do you know, if anything, about the conflict in the Kashmir region on 

the border of India and Pakistan? 97. Do you believe that you, an immediate family member, or a close friend has 

ever been affected in any way by a terrorist act or threat?

Yes _____ No _____ Not Sure _____ If yes or not sure, who was affected, and how? 

81
United States v. Sadequee: Jury Questionnaire Juror No. __________ 29

98 . Since the September 11, 2001, terrorist attacks, do you believe the 

Government’s policies and practices to prevent further terrorist attacks in 

the United States have been _____ too aggressive or intrusive, _____ not aggressive or intrusive enough, _____ about right, or are you

_____ not sure? 

Please explain your response, including any concerns you have had about 

particular policies or practices that have or have not been used: 99. What is your opinion about the war in Iraq? 100. What is your opinion about the war in Afghanistan? 101. Do you have any immediate family or close friends who are serving or have 

served in the military in the war in Iraq, the war in Afghanistan, or are in 

any way involved with counter-terrorism? Yes _____ No _____ If so, what is that person’s relationship to you, and what is or was their role? 

8282
United States v. Sadequee: Jury Questionnaire Juror No. __________ 30

102. Are any members of your extended family, including in-laws, or close 

friends of the Muslim faith? Yes _____ No _____ If yes, what is the relationship? Have you discussed their faith with them? Yes _____ No _____ If yes, please explain: 103. Are any members of your extended family, including in-laws, or close 

friends of South-Asian heritage? Yes _____ No _____ If yes, what is the relationship? 104. Do you have any knowledge about, or have you studied, the history and 

practices of Islam? Yes _____ No _____ If yes, how knowledgeable are you and what is the source of your 

knowledge? 105. Do you believe that Islam generally endorses violence?

Yes _____ No _____ Not Sure _____

83
United States v. Sadequee: Jury Questionnaire Juror No. __________ 31

106. Law enforcement witnesses will testify in this case. Does the simple fact 

that a witness is a police officer or federal agent alone _____ (a) make it more likely that you will believe that witness over other witnesses? _____ (b) make it less likely that you will believe that witness over other witnesses? _____ (c) make no difference to you, and you will evaluate the testimony of that witness as you would any other witness? If you checked (a) or (b), please explain: 107. Do you think that a person who has been arrested by the police and charged 

with a crime is probably guilty?

Yes _____ No _____ Not Sure _____ If yes or not sure, please explain: 108. How do you feel about government witnesses who have received immunity 

from prosecution or have received or may receive more lenient treatment 

after pleading guilty because they have agreed to cooperate? 

8484
United States v. Sadequee: Jury Questionnaire Juror No. __________ 32

109. If the Judge gave you an instruction on the law that differed from what you 

believe, would you be able to follow the instruction on the law even if it was 

different from your personal beliefs or what you believe the law should be?

Yes _____ No _____ Not Sure _____ If no or not sure, please explain: 110. The evidence that will be presented in this case comes from a variety of 

sources. If you cannot fairly and objectively consider evidence obtained 

from the following sources, please explain why below.

a. Electronic surveillance of private communications (wiretaps)? b. Searches of private property (such as someone’s home)? c. Physical surveillance (e.g., agents following a suspect in public 

places)? d. Interrogation (questioning) of suspects? 

85
United States v. Sadequee: Jury Questionnaire Juror No. __________ 33

111. Based on all the questions that you have read in this questionnaire, do you 

feel you could decide the case based solely on the evidence presented in 

court and the Judge’s instructions on the law, disregarding any other ideas, 

notions, or beliefs you may have about the law?

Yes _____ No _____ Not Sure _____ If no or not sure, please explain: 112. Are there any other comments you have regarding serving on this jury, or do 

you have any reason to believe you cannot be a fair and impartial juror if 

selected for the jury in this case? 113. Is there any matter not covered by this questionnaire that you think the 

attorneys or Judge might want to know about when considering whom to 

select as jurors in this case? 114. Is there any matter you would like to discuss privately with the Judge and 

the attorneys? 

8686
United States v. Sadequee: Jury Questionnaire Juror No. __________ 34

JUROR’S OATH

I declare under penalty of perjury that the information that I have provided in this 

Juror Questionnaire is true and correct. _________________ _____________________________________ DATE JUROR SIGNATURE Printed Name: ____________________________________________________ Juror Number: __________ 

87
1 

United States v. Holy Land Foundation: 

Confidential Jury Questionnaire

Hon. Jorge A. Solis

Northern District of Texas

September 4, 2008

The following questionnaire was prepared by the Northern District of Texas’s 

United States District Judge Jorge A. Solis to facilitate jury selection in a retrial 

for contributing funds to terrorism, United States v. Holy Land Foundation, No. 

3:04-cr-240 (N.D. Tex. July 26, 2004). General Instructions

This questionnaire is designed to help simplify and expedite the jury selection 

process. Although some of the questions may appear to be of a personal nature, 

please understand that the Judge and the parties must learn enough information 

about each juror’s background and experiences to select a fair and impartial jury.

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

questions write them on the form. If you don’t 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 

that the answers are yours alone. Remember, you are sworn to give true and 

complete answers to all questions. After reading your questionnaire, Judge Solis 

may personally interview you in the presence of the lawyers and give you the 

opportunity to discuss your answers. 

Do not write on the back of any page, only the front pages will be copied. If 

you need additional space to complete an answer, go to the blank pages at the 

back of the questionnaire, indicate the number of the question, and continue your 

answer.

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Solis) Juror No. __________ 2 

Juror Number ____________________________________________________

(This number may be found on the summons. Please write legibly.)

Confidential Jury Questionnaire

Please write legibly.

1. What is your age? __________

2. Are you: Male _____ Female _____

3. Do you have any problems with your hearing or vision that would make it 

difficult for you to serve as a juror? Yes _____ No _____

4. Do you have any medical condition that would make it difficult for you to 

serve as a juror on this case? Yes _____ No _____ If yes, briefly list the condition(s): _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 5. Are you (check one): Married _____ Single _____ Living with another person _____ Living with a domestic partner _____ Divorced/Separated _____ Widow/Widower _____

6. If you have any children, please list their gender, age, and, if applicable, their 

current occupation: _____________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 7. In what city do you reside? ______________________________________ a. How long have you lived in this area? ___________________________ b. What other places have you lived within the last 20 years? __________ _________________________________________________________ _________________________________________________________

_________________________________________________________ 8. Is English your first language? Yes _____ No _____

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Solis) Juror No. __________ 3 

9. What other languages do you speak, read, or understand? _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 10. Were you, your spouse, or a former spouse born outside the United States? Yes _____ No _____ If yes, please tell us who and where they were born: _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 11. a. Do you speak, read, or understand Arabic or Hebrew (or any dialect of 

Arabic or Hebrew), or did you grow up in households where those languages or any of their dialects were spoken? Yes _____ No _____

b. If you speak, read or understand the Arabic or Hebrew language (or any 

part of its dialects), would you have any difficulty relying solely upon a 

translator’s translation of the evidence? Yes _____ No _____

12. Are you: _____ Employed full-time _____ Retired

_____ Employed part-time _____ Student

_____ Homemaker _____ Disabled and unable to work

_____ Unemployed/Laid off

a. What kind of work do you do? ________________________________ _________________________________________________________ _________________________________________________________

_________________________________________________________ b. If retired or unemployed, what was your primary vocation? __________ _________________________________________________________ _________________________________________________________

_________________________________________________________ c. If a homemaker or student, please tell us what jobs outside the home (if 

any) you have had in the past two years: _________________________ _________________________________________________________ _________________________________________________________

_________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Solis) Juror No. __________ 4 

13. What is the highest grade of schooling you have completed?

_____ 8th grade or less _____ Community college

_____ Some high school _____ Some four-year college

_____ High school graduate _____ College graduate _____ Postgraduate

a. Major area(s) of study: _______________________________________ b. Degrees or certificates: ______________________________________ 14. What charitable, civic, social, union, professional, fraternal, political, recreational, or religious organizations do you belong to or participate in, and what 

offices, if any, have you held in any of these organizations? _____________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 15. Have you previously traveled outside of the United States? Yes _____ No _____ If yes, please describe where and approximately when: _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 16. Have you ever served in the military? Yes _____ No _____

a. Branch and highest rank: _____________________________________ b. Foreign stations or tours: _____________________________________ _________________________________________________________ _________________________________________________________

_________________________________________________________ 17. The judge who will preside over this case is The Honorable Jorge A. Solis, United States District Judge for the Northern District of Texas. Do you or 

anyone close to you know or have any connection with Judge Solis or any of 

his staff? Yes _____ No _____ If yes, please explain: ___________________________________________ _____________________________________________________________ _____________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Solis) Juror No. __________ 5 

18. Do you or does any relative or close friend know or have any connection 

with any of the following persons who may be seated at the counsel table for 

the government?

Assistant United States Attorney Jim Jacks Yes _____ No _____

Department of Justice Attorney Barry Jonas Yes _____ No _____

Department of Justice Attorney Elizabeth Shapiro Yes _____ No _____

Special Agent Lara Burns, FBI Yes _____ No _____

Special Agent Rob Miranda, FBI Yes _____ No _____

Special Agent Carrie Ward, FBI Yes _____ No _____

If you answered yes to any of the names above, describe your connection to 

this individual or these individuals: ________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 19. Do you or does any relative or close friend know or have any connection 

with any of the following defense lawyers or their staff?

Nancy Hollander Yes _____ No _____

Theresa Duncan Yes _____ No _____

Joshua Dratel Yes _____ No _____

Linda Moreno Yes _____ No _____

Mario Cadeddu Yes _____ No _____

Greg Westfall Yes _____ No _____

If you answered yes to any of the names above, describe your connection and 

your friend or relative’s connection to this individual or these individuals: _____________________________________________________________ _____________________________________________________________

_____________________________________________________________

_____________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Solis) Juror No. __________ 6 

20. Do you or does any relative or close friend know or have any connection 

with any of the defendants?

Holy Land Foundation for Relief and Development Yes _____ No _____

Shukri Abu Baker Yes _____ No _____

Mohammad El-Mezain Yes _____ No _____

Ghassan Elashi Yes _____ No _____

Mufid Abdulqader Yes _____ No _____

Abdulrahman Odeh Yes _____ No _____

Please explain who has the connection in detail for each individual: _____________________________________________________________ _____________________________________________________________

_____________________________________________________________

_____________________________________________________________ 21. Have you followed any criminal cases involving allegations of terrorism or 

support of terrorism? Yes _____ No _____

If yes, please list the cases and what was or is of interest to you about these 

cases: _______________________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 22. This case has received media attention that is likely to continue. Is there anything you have seen, heard, or read that would interfere with your ability to 

render a fair verdict in this case based solely on the evidence presented in 

court? Yes _____ No _____

If yes, please explain: ___________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Solis) Juror No. __________ 7 

23. This case is likely to receive media attention during the trial. The Judge 

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 Judge will be advising you periodically that you must avoid 

reading about the case in the newspaper or listening to any radio or television 

reports about the case, or reading anything about the case on the Internet. The 

Judge 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 _____

If yes, please explain: ___________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 24. What, if anything, have you seen, read, or heard about the following people 

facing charges in this case?

a. Ghassan Elashi: ____________________________________________ _________________________________________________________ _________________________________________________________ b. Shukri Abu Baker: __________________________________________ _________________________________________________________ _________________________________________________________ c. Mufid Abdulqader: _________________________________________ _________________________________________________________ _________________________________________________________ d. Mohammed El-Mezain: ______________________________________ _________________________________________________________ _________________________________________________________ e. Abdul Rahman Odeh: _______________________________________ _________________________________________________________ _________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Solis) Juror No. __________ 8 

25. Have you heard or read about any statement made by or attributed to Ghassan Elashi, Shukri Baker, Mufid Abdulqader, Mohammed El-Mezain, or Abdul Rahman Odeh? Yes _____ No _____

If yes, how would you describe the statement and to whom was it attributed, 

if you recall? __________________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 26. Based on anything you may have read, seen, or heard in the media or elsewhere, have you formed an opinion as to the guilt or innocence of any of the 

defendants in this case? Yes _____ No _____

If yes, please explain: ___________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 27. How closely have you followed the media coverage of the conflict between 

Israel and the Palestinians? Very closely _____ Somewhat closely _____ Not too closely _____

28. Have you formed any opinion or belief about the nature of that conflict that 

would prevent you from serving as a fair and impartial juror in this case? Yes _____ No _____

If yes, please explain: ___________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Solis) Juror No. __________ 9 

29. PRIOR JURY SERVICE

a. Have you ever

i. Served as a juror in a civil case? Yes _____ No _____

ii. Served on a grand jury? Yes _____ No _____

iii. Served as a juror in a criminal case? Yes _____ No _____

iv. 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 dates, 

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

a grand jury or a trial jury, (4) whether it was a criminal case or a civil 

case, (5) what the general nature of the case was (for example, robbery, 

murder, contract, negligence, medical malpractice, etc.), and (6) whether 

or not a verdict was reached.

Date

State or 

Federal 

Trial Jury

Grand 

Jury

Criminal 

or Civil Nature of Case Verdict

 

c. Is there anything about your prior jury experience that would make it difficult to serve again? Yes _____ No _____

If yes, please explain: _______________________________________ _________________________________________________________ _________________________________________________________

_________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Solis) Juror No. __________ 10

30. Have you or anyone close to you worked for, applied to, or had training with 

(check all that apply):

_____ a. Any law enforcement, security, or investigative agency, including but not limited to the police department, a state police agency, the sheriff’s department, the FBI, the DEA, the Secret Service, the Postal Inspection Service, the CIA, the BICE, the INS, 

the Department of Homeland Security, or the Department of Justice.

_____ b. A prison, jail, detention center, or probation service.

_____ c. Any city or town attorney, Attorney General, state or federal 

prosecutor, or court.

_____ d. Any law firm that practices criminal defense.

_____ e. Any accounting, banking, or financial institution.

_____ f. Any newspaper, radio, television, or other media outlet.

If yes to any of the above, please state who (relation to you), where, when, 

and the circumstances: __________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________

_____________________________________________________________ 31. Have you or a member of your family had any legal action or dispute with 

the United States or any of its agencies, or any officer, agents, or employees 

of the United States? Yes _____ No _____

If yes, please explain the nature of your interest in such proceedings: _____ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 32. Have you or a family member or close friend ever had an experience involving the police, FBI, or any other law enforcement agency, including being interviewed by or making a report to a law enforcement officer? Yes _____ No _____

If yes, please explain: ___________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Solis) Juror No. __________ 11

33. Have you or a family member or a close friend ever been arrested, charged, 

or convicted for a crime other than a traffic ticket? Yes _____ No _____

If yes, please explain who (relation to you), when, the nature of the charge, 

and the circumstances: __________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 34. a. Some of the defendants are citizens of the United States and some are 

not. Under the law, in a criminal trial, non-citizens are afforded the same 

constitutional rights as citizens. Can you follow that law? Yes _____ No _____

b. Under the law generally, the protections of free speech in our democracy 

extend both to citizens and non-citizens. Can you follow this law? Yes _____ No _____

35. Under the United States Constitution, a person accused of a crime does not 

have to testify in his defense, and his silence may not be used against him. 

Can you follow this law and not hold a defendant’s decision not to testify 

against him? Yes _____ No _____

36. The Court will instruct you that the testimony of a law enforcement officer is 

entitled to no greater weight or lesser weight than that of any other witness. 

Do you have any difficulties accepting that statement? Yes _____ No _____

37. 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.” Do you have any preconceptions of the obtaining or use of such evidence that might prevent you from considering it at 

trial? Yes _____ No _____

If yes, please explain: ___________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Solis) Juror No. __________ 12

38. At the conclusion of the case, it is the Judge’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 Judge or that would make it difficult for you to sit in 

judgment of another? Yes _____ No _____

If yes, please explain: ___________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 39. Have you or any member of your family or friends had any experience that 

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

Muslim? Yes _____ No _____

If yes, please explain: ___________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 40. Do you have any feelings about Arabs, Muslims, or the religion of Islam that 

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

open mind? Yes _____ No _____

If yes, please explain: ___________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 41. 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 proved the guilt of the defendants beyond a reasonable doubt? _____________________________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Solis) Juror No. __________ 13

42. Is there any matter not covered by this questionnaire that you feel you should 

tell us about? Yes _____ No _____

If yes, please explain: ___________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Solis) Juror No. __________ 14

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101
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 

102
United States v. Amawi: Jury Questionnaire 

Juror No. __________ 2 

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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United States v. Amawi: Jury Questionnaire 

Juror No. __________ 3 

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: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

104 104
United States v. Amawi: Jury Questionnaire 

Juror No. __________ 4 

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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United States v. Amawi: Jury Questionnaire 

Juror No. __________ 5 

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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United States v. Amawi: Jury Questionnaire 

Juror No. __________ 6 

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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United States v. Amawi: Jury Questionnaire 

Juror No. __________ 7 

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 non- military 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? _______________________________________ ____________________________________________________________ 

133
United States v. Amawi: Jury Questionnaire 

Juror No. __________ 33

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: _______________________________________________ ____________________________________________________________ 

134 134
United States v. Amawi: Jury Questionnaire 

Juror No. __________ 34

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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United States v. Amawi: Jury Questionnaire 

Juror No. __________ 35

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: _________________________________________ ____________________________________________________________ 

136 136
United States v. Amawi: Jury Questionnaire 

Juror No. __________ 36

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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United States v. Amawi: Jury Questionnaire 

Juror No. __________ 37

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

138 138
United States v. Amawi: Jury Questionnaire 

Juror No. __________ 38

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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United States v. Amawi: Jury Questionnaire 

Juror No. __________ 39

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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United States v. Amawi: Jury Questionnaire 

Juror No. __________ 40

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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United States v. Amawi: Jury Questionnaire 

Juror No. __________ 41

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: _______________________________________________ ____________________________________________________________ 

142 142
United States v. Amawi: Jury Questionnaire 

Juror No. __________ 42

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: __________________________________________ ____________________________________________________________ 

143
1 

United States v. Batiste: 

Voir Dire Questions 

Hon. Joan A. Lenard

Southern District of Florida

September 18, 2007 

The following voir dire questions were prepared by the Southern District of Florida s United States District Judge Joan A. Lenard for jury selection in a prosecution for terrorism, United States v. Batiste, No. 1:06-cr-20373 (S.D. Fla. June 22, 

2006). Judge Lenard does not use jury questionnaires. These questions are designed to be asked in three phases: first are questions directed to the whole panel, 

second are individual general qualification questions, and third are more sensitive 

case-specific individual questions. The court of appeals found Judge Lenards 

voir dire procedures in a previous case a meticulous model. United States v. 

Campa, 459 F.3d 1121 (11th Cir. 2006). Phase 1: Questions for the Whole Panel

1. Are you familiar with the area of N.W. 62nd Street and N.W. 15th Avenue?

2. Have you or a member of your family or close friend had either a positive or 

negative experience with law enforcement of any kind that would make it 

difficult for you to listen to the evidence in this case and be fair to both the 

government and the defendants?

3. In this case, you may hear testimony that the government used cooperating 

individuals, CIs or informants, to work in an undercover capacity who were 

paid or received other benefits. Is there any member of the jury panel who 

has such strong feelings one way or the other about the use of such cooperating individuals such that you would not be able to sit and listen to this evidence and be fair to both the government and the defendants?

4. The evidence in this case may also include the recordings of conversations 

that were recorded without the knowledge of some of the participants 

through the lawful use of electronic devices commonly known as bugs or 

wiretaps. Is there any member of the jury panel who has such strong feelings 

one way or the other regarding the use of bugs or wiretaps such that you 

would not be able to sit and listen to this evidence and be fair to both the 

government and the defendants?

5. In this case, you may hear evidence of the recordings of conversations that 

were recorded without the knowledge of all of the participants through the 

use of a body wire, by secretly taping telephone conversations, or by secretly 

recorded videotapes. Is there any member of the jury panel who has such 

strong feelings one way or the other that you would not be able to sit and listen to this evidence and be fair to both the government and the defendants?

6. In this case, you may hear evidence that was obtained from photographic and

physical surveillance as well as evidence seized pursuant to lawful searches 

144 144
United States v. Batiste: Voir Dire Questions

2 

of various places including the homes of some of the defendants. Is there any 

member of the jury panel who has such strong feelings one way or the other 

that you would not be able to sit and listen to this evidence and be fair to both 

the government and the defendants?

7. Is there any member of the jury panel who would not be able to listen to the 

testimony of a law enforcement officer and be fair to both the prosecution 

and the defendants? Or . . . be more likely or less likely to believe the testimony of a law enforcement officer solely because of the officer s position?

8. Does everyone understand that any person charged with a crime is presumed 

innocent?

9. Do you all understand that the indictment in a criminal case is the accusatory 

paper which states the charge or charges to be determined at the trial; it is not 

evidence against the defendant or anyone else?

10. Do you all understand that the government has the burden of proving a defendant guilty beyond a reasonable doubt?

11. Is there anyone who would hold the government to a higher or lower burden 

of proof?

12. Do you all understand that the case of each defendant and the evidence pertaining to each defendant should be considered separately and individually 

by the jury?

13. If you are chosen as a juror in this case if the government proves its case 

against a defendant beyond a reasonable doubt, would you be able to return a 

verdict of guilty? Likewise, if the government fails to prove its case against 

the defendant beyond a reasonable doubt, would you be able to return a verdict of not guilty?

14. Is there any member of the jury panel who feels that if the government goes 

to the trouble of bringing someone to trial, then the person is probably 

guilty?

15. Is there any member of the jury panel who feels that a defendant in a criminal 

case should testify or produce some evidence to prove that he or she is not 

guilty?

16. Is there any member of the jury panel who feels that the law does too much 

to protect the rights of the accused and not enough to protect the rights 

of crime victims and their families, such that it would affect your ability to 

be a fair and impartial juror in this case?

17. Is there any member of the jury panel who feels that individuals are treated 

differently by the criminal justice system based on their race, creed, or national origin?

18. Is there any member of the jury panel who you yourself or your spouse or 

family member has ever been audited or had a dispute with any agency or 

department of the U.S. government?

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United States v. Batiste: Voir Dire Questions

3 

19. Is there a member of the jury panel who thinks the government has gone 

overboard in its efforts to fight terrorism?

20. Is there any member of the jury panel who has any experience or formal 

training in the area of martial arts?

21. Is there any member of the jury panel who you yourself or someone in your 

home owns a firearm? How many and what kind?

22. Is there any member of the jury panel who knows any other member of the 

jury panel?

23. In this case, you may hear testimony from witnesses who are of a different 

religion from your own. Is there any member of the jury panel who has 

strong feelings one way or the other such that you would not be able to sit 

and listen to this evidence and be fair to both the government and the defendants?

24. In this case, you may also hear evidence from certain witnesses who are from 

the Middle East. Is there any member of the jury panel who has strong feelings one way or the other such that you would not be able to sit and listen to 

this evidence and be fair to both the government and the defendants?

25. This case may receive media attention. It is very important that this case is

decided solely on the evidence presented in the courtroom and not based on 

anything that may be said outside the courtroom. Accordingly, you will be 

instructed if you are chosen as a juror that you must avoid reading about the 

case in newspapers or listening to any radio or television reports or viewing 

the Internet. Will you be able to follow my instructions regarding media coverage?

Phase 2: Individual Qualification Questions

1. How old are you?

2. What is your place of birth?

3. Where were your parents born?

4. What type of work do you do (without stating the name of the business, corporation, store, or the like)? 

5. What is your general area of residence (i.e., Cutler Ridge, North Miami, 

etc.)? What is your length of time in that community? (If less than 5 years at 

your current residence, please indicate your prior town or community.)

6. Do you own your current residence or do you rent your current residence? 

Are you living with family or friends?

7. Have you ever lived outside the United States for more than 6 months? What 

countries and for how long?

8. What is your marital status (married, single, divorced)? 

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United States v. Batiste: Voir Dire Questions

4 

9. If you live with someone else, what is that person s occupation (without stating where they work, the name of the business, corporation, store, or the 

like)? 

10. What are the ages of your children, if any? If employed, what type of work 

do they do (without stating where they work)? 

11. Do you have any children that live outside the United States?

12. Do you speak, write, or understand a language other than English? What language?

13. Do you have any hobbies? What do you do in your spare time?

14. What was the last grade you completed in school? (If you have a degree or 

certificate, what was your major area of study?)

15. Have you attended law school or a paralegal institute?

16. What are your major sources of news, if any: the newspaper, television, radio, or the Internet?

17. Are any of your family members or close friends employed in the criminal 

justice system (i.e., law enforcement officers, probation officers, criminal defense lawyers, private investigators)? 

18. Have you, your spouse, or a family member ever worked for (answer yes or 

no for each): 

a prosecutor s office?

a public defender s office?

a federal or state investigative agency?

a federal agency or a medical facility?

19. Do you have any advanced knowledge or special training in the field of videotaping or digital recording?

20. Do you or your spouse have any education, training, or employment experience in any of the following fields? 

security

intelligence

law

psychology or psychiatry

social work

corrections

religion

media or Communications

21. Are you a vendor or a contractor for the United States Government or is your 

employer a vendor or a contractor for the United States Government?

22. Have you, your spouse, or a family member ever applied or sought employment in law enforcement (yes or no)? (If yes, what happened with the application?)

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United States v. Batiste: Voir Dire Questions

5 

23. Have you ever been a victim of a crime?

A. Was it reported? Was anyone arrested? What happened with the case?

B. Are you generally satisfied or dissatisfied with the way you were treated 

by law enforcement officials and the justice system? 24. Have you ever been a witness to a crime? A. Was it reported? Was anyone arrested? What happened with the case? B. Are you generally satisfied or dissatisfied with the way you were treated 

by law enforcement and the judicial system? 25. Have you ever testified in a trial or deposition?

26. Have you ever been accused of, charged with, or convicted of any crime or 

been the subject of a criminal investigation, other than a minor traffic violation?

27. Has a family member or close friend ever been accused of, charged with, or 

convicted of any crime or been the subject of a criminal investigation, other 

than a minor traffic violation?

28. Do you belong to a church, synagogue, or other religious organization and 

follow its teachings (yes or no only)? 

29. Would any of your religious, philosophic, or moral beliefs preclude you from 

sitting in judgment of another person or deliberating with others?

30. Have you previously served on a petit (trial) jury? If yes, was it in federal or 

state court? Was it a criminal or a civil trial? Did the jury reach a verdict? 

Did you serve as the foreperson?

31. Have you previously served on a grand jury? If yes, was it in federal or state 

court? Did you serve as the foreperson?

32. Do you have any loss of hearing, loss of sight, or any physical or emotional 

impairment that would make it difficult for you to participate as a juror?

33. Do you have any problems understanding or reading the English language 

which would make jury duty difficult?

34. Are you currently taking any medication or other substance that would have 

an impact on your jury service?

35. Do you own or regularly use a computer or access the Internet?

Phase 3: Case-Specific Individual Questions

1. In this case, the government has alleged that the defendants were engaged in 

conspiracies to commit various violations of federal laws regarding terrorist 

activities. The charges include conspiracies or agreements to provide material support and resources to agents of al-Qaeda in conspiring to blow up the Sears 

148 148
United States v. Batiste: Voir Dire Questions

6 

Tower in Chicago and several federal buildings in a planned war against the 

United States.

Given that, is there anything that would prevent you from being able to 

sit and listen to the evidence in this case and be fair to both the government 

and the defendants?

2. As I indicated to you earlier, due to the publicity surrounding this case and to 

prevent any outside influence from the public, I have determined that there 

will be an anonymous jury, whereby your name, address, place of employment and any other identifying information will be withheld from the public 

and the parties in this case. Do you have such strong feelings about these 

procedures that you would not be able to be fair and impartial to both the 

government and the defendants?

3. As I indicated to you earlier, due to the publicity surrounding this case and to 

prevent any outside influence from the public, I have determined that the 

U.S. Marshal will provide transportation to and from the courthouse for the 

jurors during the trial. Do you have such strong feelings about this provided 

transportation that you would not be able to be fair and impartial to both the 

government and the defendants?

4. I will instruct you in this case that each defendant has entered a plea of not 

guilty and under the law is presumed innocent. Given the procedures regarding the anonymous jury and provided transportation, will you be able to follow the Court s instruction on the law?

5. In this case, you may hear evidence that the government used informants 

who were not United States citizens and who posed as terrorist-agents of alQaeda.

Do you have such strong feelings one way or the other that you would 

not be able to sit and listen to this evidence and be fair to both the government and the defendants? 6. Have you acquired any information from newspapers, television, conversations, or any other sources about this case? From what source did you acquire

this information?

7. Do you read the Miami Herald, New Times, or Sun Sentinel news publications either in print or on line?

8. Have you read anything in any newspaper or on the Internet, or have you 

seen anything on television or heard anything on the radio, about this case?

9. How closely have you followed the course of proceedings leading up to this 

trial?

10. Have you discussed this case with anyone? If so, with whom?

11. Do you have an open mind regarding this case?

12. Have you formed an opinion regarding any of the defendants based upon any 

outside information? What is your opinion?

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United States v. Batiste: Voir Dire Questions

7 

13. Would your opinion affect your ability to determine the defendants guilt

based solely on the evidence presented at trial?

14. Do you have any beliefs, thoughts, or opinions that may cause you to decide 

this case on anything other than the evidence you will here at trial? What are 

they?

15. Can you set those beliefs, thoughts, or opinions aside and decide this case 

based on the evidence that is admitted in this courtroom and the law as the 

Court instructs you? If yes, will you do that?

16. Are you knowledgeable about the history and practice of Islam?

17. Are you knowledgeable about the history and practices of the Moorish 

Science Temple?

18. Are you knowledgeable about the Universal Divine Saviors?

19. Are you a member of any type of Masonic lodge? Are you knowledgeable 

about the history, teachings, or practices of the Masons?

20. Have you, your spouse, or any of your family members ever visited the Middle East? If so, when was the trip? What countries did you visit? What was 

the purpose of your trip?

21. Do you, family members, or close friends have any prior or present military 

service? If yes, what was your or their place of service?

Did you or they serve in combat? Where? Were you injured or were they 

injured or did they suffer loss of life? Were you or they ever in the military 

police or shore patrol? Have you or they had any disciplinary action taken 

against you or them? Did you or they receive an honorable discharge? What 

was your or their rank at discharge? 22. Have you, any members of your family, or close friends had any personal 

experience with acts of terrorism?

23. Do you know or do you have a family member or friend who knows someone who was a victim of a terrorist attack?

24. Have the events of September 11th or any other terrorist act affected you to 

such an extent that it would make it difficult for you to sit and listen to the 

evidence in this case and be fair to both the government and the defendants?

25. Have you, any family member, or a close friend lost a job or a business contract or experienced any other financial hardship as a result of September 

11th or any other terrorist attack?

26. Do you have an opinion as to who was responsible for the attack on the United States on September 11, 2001? If the answer is yes, who do you think was

responsible?

27. A recent trial conducted in this district concerned a defendant named Jose 

Padilla. That case has no connection whatsoever with the case against the defendants here.

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United States v. Batiste: Voir Dire Questions

8 

Is there anything about the case of Jose Padilla that would prevent you 

from sitting and listening to the evidence in this case and being fair to both 

the government and the defendants? 28. Is there anything else you think the Court or the attorneys should know that 

might influence your ability to fairly and impartially judge the evidence in 

this case and follow the Court s instructions on the law?

151
1 

United States v. Holy Land Foundation: 

Confidential Jury Questionnaire

Hon. A. Joe Fish

Northern District of Texas

July 16, 2007

The following questionnaire was prepared by the Northern District of Texas’s 

United States District Judge A. Joe Fish to facilitate jury selection in a prosecution for contributing funds to terrorism, United States v. Holy Land Foundation, No. 3:04-cr-240 (N.D. Tex. July 26, 2004). General Instructions

This questionnaire is designed to help simplify and expedite the jury selection 

process. 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. 

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

questions, write them on the form. If you don’t 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 

that the answers be yours alone. Remember, you are sworn to give true and complete answers to all questions. After reading your questionnaire, Judge Fish may 

personally interview you in the presence of the lawyers and give you an opportunity to discuss your answers.

Do not write on the back of any page; only the front pages will be copied. If 

you need additional space to complete an answer, go to the blank pages at the 

back of the questionnaire, indicate the number of the question, and continue your 

answer. 

152 152
United States v. Holy Land Foundation: Jury Questionnaire (Judge Fish) Juror No. __________ 2 

Confidential Jury Questionnaire

Please write legibly.

1. What is your age? __________

2. Are you: Male _____ Female _____

3. Do you have any problems with your hearing or vision that would make it 

difficult for you to serve as a juror? Yes _____ No _____

4. Do you have any medical condition that would make it difficult for you to 

serve as a juror on this case? Yes _____ No _____ If yes, briefly list the condition(s): _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 5. Are you (check one): Married _____ Single _____ Living with another person _____ Living with a domestic partner _____ Divorced/Separated _____ Widow/Widower _____

6. If you have any children, please list their gender and age: _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 7. In what city do you reside? ______________________________________ a. How long have you lived in this area? ___________________________ b. What other places have you lived within the last 20 years? __________ _________________________________________________________ _________________________________________________________

_________________________________________________________ 8. Is English your first language? Yes _____ No _____

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Fish) Juror No. __________ 3 

9. What other languages do you speak, read, or understand? _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 10. Were you, your spouse, or a former spouse born outside the United States? Yes _____ No _____ If yes, please tell us who and where they were born: _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 11. Do you speak, read, or understand Arabic or Hebrew (or any dialect of Arabic or Hebrew), or did you grow up in households where those languages or 

any of their dialects were spoken? Yes _____ No _____

a. If you speak, read, or understand the Arabic or Hebrew language (or any 

of its dialects), would you have any difficulty relying solely upon a translator’s translation of the evidence? Yes _____ No _____

12. Are you: _____ Employed full-time _____ Retired

_____ Employed part-time _____ Student

_____ Homemaker _____ Disabled and unable to work

_____ Unemployed/Laid off

a. What kind of work do you do? ________________________________ _________________________________________________________ _________________________________________________________

_________________________________________________________ b. If retired or unemployed, what was your primary vocation? __________ _________________________________________________________ _________________________________________________________

_________________________________________________________ c. If homemaker or student, please tell us what jobs outside the home (if 

any) you have had in the past two years: _________________________ _________________________________________________________ _________________________________________________________

_________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Fish) Juror No. __________ 4 

13. What is the highest grade of schooling you have completed?

_____ 8th grade or less _____ Community college

_____ Some high school _____ Some four-year college

_____ High school graduate _____ College graduate _____ Postgraduate

a. Major area(s) of study: _______________________________________ b. Degrees or certificates: ______________________________________ 14. What charitable, civic, social, union, professional, fraternal, political, recreational, or religious organizations do you belong to or participate in, and what 

offices, if any, have you held in any of these organizations? _____________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 15. Have you previously traveled outside of the United States? Yes _____ No _____ If yes, please describe where and approximately when: _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 16. Have you ever served in the military? Yes _____ No _____

a. Branch and highest rank: _____________________________________ b. Foreign stations or tours: _____________________________________ _________________________________________________________ _________________________________________________________

_________________________________________________________ 17. The judge who will preside over this case is The Honorable Joe Fish, Chief 

Judge of the United States District Court for the Northern District of Texas. 

Do you or anyone close to you know or have any connection with Judge Fish 

or any of his staff? Yes _____ No _____ If yes, please explain: ___________________________________________ _____________________________________________________________ _____________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Fish) Juror No. __________ 5 

18. Do you or does any relative or close friend know or have any connection 

with any of the following persons who may be seated at the counsel table for 

the government?

Assistant United States Attorney Jim Jacks Yes _____ No _____

Assistant United States Attorney Nathan Garrett Yes _____ No _____

Department of Justice Attorney Barry Jonas Yes _____ No _____

Department of Justice Attorney Betsy Shapiro Yes _____ No _____

Special Agent Lara Burns, FBI Yes _____ No _____

Special Agent Rob Miranda, FBI Yes _____ No _____

Special Agent Carrie Ward, FBI Yes _____ No _____

If you answered yes to any of the names above, describe your connection and 

your friend or relative’s connection to this individual or these individuals: _____________________________________________________________ _____________________________________________________________

_____________________________________________________________

_____________________________________________________________ 19. Do you or does any relative or close friend know or have any connection 

with any of the following defense lawyers or their staff?

John Boyd Yes _____ No _____

Nancy Hollander Yes _____ No _____

Theresa Duncan Yes _____ No _____

Joshua Dratel Yes _____ No _____

Linda Moreno Yes _____ No _____

Mario Cadeddu Yes _____ No _____

Greg Westfall Yes _____ No _____

If you answered yes to any of the names above, describe your connection and 

your friend or relative’s connection to this individual or these individuals: _____________________________________________________________ _____________________________________________________________

_____________________________________________________________

_____________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Fish) Juror No. __________ 6 

20. Do you or does any relative or close friend know or have any connection 

with any of the defendants?

Holy Land Foundation for Relief and Development Yes _____ No _____

Shukri Abu Baker Yes _____ No _____

Mohammad El-Mezain Yes _____ No _____

Ghassan Elashi Yes _____ No _____

Mufid Abdulqader Yes _____ No _____

Abdulrahman Odeh Yes _____ No _____

Haitham Maghawri Yes _____ No _____

Akram Mishal Yes _____ No _____

Please explain who has the connection in detail for each individual: _____________________________________________________________ _____________________________________________________________

_____________________________________________________________

_____________________________________________________________ 21. Have you followed any criminal cases involving allegations of terrorism or 

support of terrorism? Yes _____ No _____

If yes, please list the cases and what was or is of interest to you about these 

cases: _______________________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 22. This case has received previous media attention. Is there anything you have 

seen, heard, or read about it that would interfere with your ability to render a 

fair verdict in this case based solely on the evidence presented in court? Yes _____ No _____

If yes, please explain: ___________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Fish) Juror No. __________ 7 

23. This case is likely to receive media attention during the trial. 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, or reading anything about the case on the Internet. 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 _____

If yes, please explain: ___________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 24. What, if anything, have you seen, read, or heard about the following people 

facing charges in this case?

a. Ghassan Elashi: ____________________________________________ _________________________________________________________ _________________________________________________________ b. Shukri Abu Baker: __________________________________________ _________________________________________________________ _________________________________________________________ c. Mufid Abdulqader: _________________________________________ _________________________________________________________ _________________________________________________________ d. Mohammed El-Mezain: ______________________________________ _________________________________________________________ _________________________________________________________ e. Abdul Rahman Odeh: _______________________________________ _________________________________________________________ _________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Fish) Juror No. __________ 8 

25. Have you heard or read about any statement made by or attributed to Ghassan Elashi, Shukri Baker, Mufid Abdulqader, Mohammed El-Mezain, or Abdul Rahman Odeh? Yes _____ No _____

If yes, how would you describe the statement and to whom was it attributed, 

if you recall? __________________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 26. Based on anything you may have read, seen, or heard in the media or elsewhere, have you formed an opinion as to the guilt or innocence of any of the 

defendants in this case? Yes _____ No _____

If yes, please explain: ___________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 27. How closely have you followed the media coverage of the conflict between 

Israel and the Palestinians? Very closely _____ Somewhat closely _____ Not too closely _____

28. Have you formed any opinion or belief about the nature of that conflict that 

would prevent you from serving as a fair and impartial juror in this case? Yes _____ No _____

If yes, please explain briefly: _____________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Fish) Juror No. __________ 9 

29. PRIOR JURY SERVICE

a. Have you ever

i. Served as a juror in a civil case? Yes _____ No _____

ii. Served on a grand jury? Yes _____ No _____

iii. Served as a juror in a criminal case? Yes _____ No _____

iv. 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 dates, 

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

a grand jury or a trial jury, (4) whether it was a criminal case or a civil 

case, (5) what the general nature of the case was (for example, robbery, 

murder, contract, negligence, medical malpractice, etc.), and (6) whether 

or not a verdict was reached.

Date

State or 

Federal 

Trial Jury

Grand 

Jury

Criminal 

or Civil Nature of Case Verdict

 

c. Is there anything about your prior jury experience that would make it difficult to serve again? Yes _____ No _____

If yes, please explain: _______________________________________ _________________________________________________________ _________________________________________________________

_________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Fish) Juror No. __________ 10

30. Have you or anyone close to you worked for, applied to, or had training with 

(check all that apply):

_____ a. Any law enforcement, security, or investigative agency, including but not limited to police department, state police agency, sheriff’s department, the FBI, DEA, Secret Service, Postal Inspection Service, CIA, BICE, INS, Department of Homeland Security, and the Department of Justice.

_____ b. A prison, jail, detention center, or probation service.

_____ c. Any city or town attorney, Attorney General, state or federal 

prosecutor, or court.

_____ d. Any law firm that practices criminal defense.

_____ e. Any accounting, banking, or financial institution. _____ f. Any newspaper, radio, television, or other media outlet.

If yes to any of the above, please state who (relation to you), where, when, 

and circumstances: _____________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________

_____________________________________________________________ 31. Have you or a member of your family had any legal action or dispute with 

the United States or any of its agencies, or any officer, agents, or employees 

of the United States? Yes _____ No _____

If yes, please explain the nature of your interest in such proceedings: _____ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 32. Have you or a family member or close friend ever had an experience involving the police, FBI, or any other law enforcement agency, including being interviewed by or making a report to a law enforcement officer? Yes _____ No _____

If yes, please explain: ___________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Fish) Juror No. __________ 11

33. Have you or a family member or a close friend ever been arrested, charged, 

or convicted for a crime other than a traffic ticket? Yes _____ No _____

If yes, please explain who (relation to you), when, nature of the charge, and 

circumstances: ________________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 34. Some of the defendants are citizens of the United States and some are not. 

Would you afford each of the defendants the same consideration in evaluating the evidence? Yes _____ No _____

35. Under the United States Constitution, a person accused of a crime does not 

have to testify in his defense, and his silence may not be used against him. 

Could you abide by this constitutional requirement? Yes _____ No _____

36. The Court will instruct you that the testimony of a law enforcement officer is 

entitled to no greater weight or lesser weight than that of any other witness. 

Do you have any difficulty accepting that statement? Yes _____ No _____

37. 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.” Do you have any preconceptions of the obtaining or use of such evidence that might prevent you from considering it at 

trial? Yes _____ No _____

If yes, please explain: ___________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Fish) Juror No. __________ 12

38. 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 or that would make it difficult for you to sit in 

judgment of another? Yes _____ No _____

If yes, please explain: ___________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 39. 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 proved the guilt of the defendants beyond a reasonable doubt? _____________________________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 40. Is there any matter not covered by this questionnaire that you feel you should 

tell us about? Yes _____ No _____

If yes, please explain: ___________________________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Fish) Juror No. __________ 13

(EXTRA PAGE FOR FURTHER ANSWERS) ________________________________________________________________ ________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________ ________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

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________________________________________________________________

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________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

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United States v. Holy Land Foundation: Jury Questionnaire (Judge Fish) Juror No. __________ 14

JUROR’S OATH:

I declare under penalty of perjury that the information that I have provided in this 

jury questionnaire, and any attachments, is true and correct. I further declare that 

I have completed this questionnaire without anyone’s assistance. _________________________________

Juror Name _________________________________ Date

165
1 

United States v. Sabir: 

Jury Questionnaire

Hon. Loretta A. Preska

Southern District of New York

April 24, 2007 

The following questionnaire was prepared by the Southern District of New 

York’s United States District Judge Loretta A. Preska to facilitate jury selection 

in a prosecution for agreeing to provide medical care to members of al-Qaeda, United States v. Sabir, No. 1:05-cr-673 (S.D.N.Y. June 27, 2005). 

Jury Questionnaire

A. Instructions For Filling Out This Questionnaire

Where indicated, check the line for “Yes” or “No.” Furnish answers, explanations, or details in the space provided. If you need additional space to answer any 

question, use the last page of the questionnaire, and state the question number. 

Please do not write on the back of any page.

B. Introduction

The purpose of these questions is to enable the parties and the Court to select a 

fair and impartial jury. These questions, and your answers to them, are in no 

sense evidence in the case, and you should not regard them, or any thoughts they 

may raise in your mind, as having any bearing on the case. The questions are not 

meant to embarrass you in any way, but only to elicit information necessary to 

permit the parties to make an informed choice of jurors for the case.

Your oath obligates you to give fair and truthful answers to these questions. 

It is your solemn duty to serve as a fair and impartial juror if you are able to do 

so, but it is equally your solemn duty not to serve if for any reason you cannot be 

fair and impartial. Accordingly, you must disclose to this Court any fact or belief 

that might prevent you from serving as a fair and impartial juror here.

This is a criminal case, which means that the defendant is punishable under 

the laws of the United States if the jury finds him guilty beyond a reasonable 

doubt of the crimes charged. The defendant has no burden to prove that he is not 

guilty. Rather, it is the Government’s burden to establish the defendant’s guilt 

beyond a reasonable doubt. I will instruct the jury on what this burden of proof 

means after the evidence is presented.

The charge against the defendant is set forth in an indictment. An indictment 

is merely an accusation, a statement of what the Government intends to prove. It 

is not evidence against the defendant, and no inference may be drawn against him 

from its existence. The defendant has pleaded not guilty to the indictment—that 

is, he has denied the charges made by the Government. The accusations, and the 

166 166
United States v. Sabir: Jury Questionnaire

2 

denial by the defendant of those accusations, raise issues of fact that must be decided by a jury on the basis of evidence presented in court.

The only evidence which you may consider as bearing on the defendant’s 

guilt is the evidence received in the trial, which will consist of the testimony of 

witnesses under oath, the exhibits that the Court receives in evidence, and any 

stipulations that the parties may enter into. The Court has no knowledge of the 

facts of this case, and nothing in this questionnaire constitutes evidence. However, the following is a brief summary of the accusations of the indictment, so that 

you will understand the reasons for certain questions that will be put to you.

The defendant in this case is Rafiq Sabir. He is charged in an indictment 

containing two counts or charges. The first count charges the defendant with conspiring with others to provide material support or resources to the al-Qaeda terrorist organization, in the form of personnel, training, and expert advice or assistance. The indictment alleges that defendant Sabir conspired with another individual, Tarik Shah, to provide martial arts training and medical services to alQaeda. The second count charges the defendant with actually providing, or attempting to provide, material support or resources to al-Qaeda in those same 

forms.

1. Do you feel that you could not view fairly and impartially a case involving 

such charges or that the actions involved in such charges should not be a 

crime? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ C. Preliminary Questions

2. Do you have any problem with hearing or vision or any other problem 

which would prevent you from giving full attention to all of the evidence of 

this trial? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Sabir: Jury Questionnaire

3 

3. Are you taking any medication or receiving any medical treatment that 

would make it difficult for you to give full attention to the evidence at this 

trial? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 4. Do you have any difficulty reading or understanding English? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ D. Case Information

5. The Court and the parties estimate this case will last approximately three 

weeks, although one can never be precise as to how long a trial will take.

We expect that the jury will be sitting four days per week (Monday through 

Thursday), but may sit on Fridays as well if deemed necessary by the Court.

The Court recognizes that jury service places a burden on those jurors called 

to serve. Nonetheless, the right to a jury trial is an important constitutional 

right that requires the Court to call upon citizens such as yourselves to make 

some personal sacrifice. Bearing in mind the importance of a trial by jury, 

and that mere inconvenience or the usual financial hardships of jury service 

will be insufficient to excuse a prospective juror, do you have reasons why 

you feel that jury service for such a period of time would pose a particularly 

severe burden requiring that you be excused from consideration? _____ Yes _____ No

If yes, briefly explain the hardship: _______________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Sabir: Jury Questionnaire

4 

6. Do you or does any relative or close friend of yours know or have any 

connection with any of the following persons representing or assisting the 

Government in this case?

Assistant United States Attorney Jennifer G. Rodgers

Assistant United States Attorney Karl Metzner

Assistant United States Attorney Victor L. Hou

Special Agent Brian Murphy

Paralegal Specialist Jenna Kidney

_____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 7. Do you or does any relative or close friend of yours know or have any 

connection with any of the following persons representing or assisting the 

defendant in this case?

Edward D. Wilford

Natalie Todd

_____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 8. Do you or does any relative or close friend of yours know or have any 

connection with the defendant, Rafiq Sabir? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Sabir: Jury Questionnaire

5 

9. Have you seen, heard, or read anything about the defendant or about this 

case, or about the charges in the indictment? This includes not only through 

the media but anything you may have heard from friends, relatives, or co- workers. _____ Yes _____ No

If yes, what have you seen, heard, or read? _________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 10. Do you or any relative or close friend of yours know or have any connection 

with any of the individuals listed on “Attachment A” (at the end of the 

questionnaire) who may be witnesses or who may be mentioned at trial? _____ Yes _____ No

If yes, please list the individual’s name here and explain the connection. (If 

you need extra space, use the “Explanation Sheet” at the end of this 

questionnaire.) ________________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 11. The indictment also includes charges filed against another person, but only 

defendant Sabir is on trial today. You may not draw any inference, favorable 

or unfavorable, toward the Government or the defendant on trial, from the 

fact that the other individual named in the indictment is not also on trial 

here. You also may not speculate as to the reason why that other person is 

not on trial. Would you have any difficulty following this instruction? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 12. Do you have any bias or prejudice for or against the Government in a 

criminal case? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Sabir: Jury Questionnaire

6 

13. Do you have any bias or strong feeling for or against the United States 

Government, the United States Attorney’s Office, any federal or state law 

enforcement agency, or people who work in law enforcement? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 14. During this trial, you will hear evidence in the form of tape recordings of 

conversations with a member of the charged conspiracy. These recordings 

were made without the knowledge of the alleged conspirator but with the 

consent and agreement of at least one other party to the conversation. The 

use of this procedure to gather evidence is perfectly lawful, and the 

Government is entitled to use the tape recordings in this case. Do you have 

any feelings about the use of consensual recordings that would make it 

difficult for you to render a fair and impartial verdict? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 15. You will also hear evidence in this case resulting from the use of a court- authorized wiretap by the FBI. I instruct you now that the Court has 

determined that the use of wiretaps in this case was lawful and did not 

violate the rights of the defendant. Moreover, wiretaps often are necessary 

law enforcement tools. Do you have any general feeling about the 

Government’s use of a wiretap that would make it difficult for you to render 

a wholly fair and impartial verdict? Would you have any bias for or against 

the Government because of evidence obtained in this manner? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Sabir: Jury Questionnaire

7 

16. You will hear testimony in this case from a federal law enforcement officer 

who participated in the investigation of the offenses described in the 

indictment in an undercover capacity. I advise you that the use of 

undercover agents is legal and often a necessary law enforcement tool. Do 

you have any general feeling about the Government’s use of undercover 

agents that would make it difficult for you to render a wholly fair and 

impartial verdict? Would you have any bias for or against the Government 

because of evidence presented in this manner? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 17. You will hear testimony during this trial concerning the use of a confidential 

informant during the investigation of the case. I want to advise you that the 

use of informants in the context of this case is perfectly legal and is often a 

necessary law enforcement tool. Do you have any general feelings about the 

Government’s use of informants that would make it difficult for you to 

render a wholly fair and impartial verdict? Would you have a bias for or 

against the Government because of the use of evidence obtained from 

informants? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 18. Some of the evidence in this trial may also come from searches by law 

enforcement officers. I instruct you now that the Court has determined that 

none of the searches in this case violated the rights of the defendant. In other 

words, it is proper for the evidence from these searches to be introduced at 

trial for your consideration. With that in mind, do you have any feelings 

about searches conducted by law enforcement officers that would make it 

difficult for you to consider such evidence fairly and impartially as you 

would any other evidence? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Sabir: Jury Questionnaire

8 

19. You may hear testimony in this case concerning the use of visual or physical 

surveillances conducted by law enforcement officers. I instruct you that this 

investigative technique in the context of this case was legal and is often a 

necessary law enforcement tool. Do you have any feelings about the use of 

visual or physical surveillance that would make it difficult for you to render 

a fair and impartial verdict? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ E. Personal and Family Information

20. Your age: __________

21. Your gender: _____Female _____ Male

22. Address information:

a. County in which you live: ________________________________________________________ b. Town, area, or neighborhood in which you live: ________________________________________________________ c. Number of years there: __________

d. Do you live in a single family home, an apartment, a cooperative, or a 

condominium? ________________________________________________________ 23. Your present marital status: _____ Married _____ Single (never married) _____ Widowed _____ Separated or Divorced

24. a. Do you have children? _____ Yes _____ No

b. If yes, state the age of each child: ________________________________________________________ c. Are you the primary caretaker of your child or children? ________________________________________________________ 

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United States v. Sabir: Jury Questionnaire

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25. What is the highest grade that you completed in school? Circle the 

appropriate answer:

1–7 8 9 10 11 12

College: 1 yr. 2 yrs. 3 yrs. 4 yrs.

Vocational or Technical School: 1 yr. 2 yrs. 3 yrs. 4 yrs.

Graduate or Professional School—Specify: _________________________ 26. If you continued your education beyond high school, what was your major 

area of study? If more than one, please list all. ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 27. Do you work outside the home? _____ Yes _____ No

If yes, how are you employed? (If now retired, please describe the work 

from which you have retired. If presently unemployed, please describe your 

last employment or your vocation.) ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 28. If you are married or cohabitating, does your spouse or partner work outside 

the home? _____ Yes _____ No _____ Not Applicable

If yes, how is your spouse or partner employed? (If now retired, please 

describe the work from which your spouse or partner has retired.) ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Sabir: Jury Questionnaire

10

29. Are you a lawyer? _____ Yes _____ No

If yes, state the general areas of law (e.g., criminal or civil, litigation or 

corporate, etc.) that you have had experience practicing and roughly how 

long you have practiced in each area. ____________________________________________________________ ____________________________________________________________

____________________________________________________________ If no, have you had any legal or paralegal training? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ Do you have any relatives or close friends who are lawyers or who have 

legal training? _____ Yes _____ No

If yes, state the general areas of law (e.g., criminal or civil, litigation or 

corporate, etc.) in which your relatives or close friends have had experience 

practicing and roughly how long each has practiced in each area. ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 30. Have you or any relative or close friend ever had dealings with the United 

States Attorney’s office? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Sabir: Jury Questionnaire

11

31. Have you, any member of your family, or any close friend ever been 

charged with any crime, or been the subject of investigation or accusation by 

any governmental body? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 32. Are you, any member of your family, or any close friend now under 

subpoena, or about to be, in any criminal case or investigation? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 33. Have you, any member of your family, or any close friend ever been 

questioned in any matter by the United States Department of Justice, the 

Federal Bureau of Investigation, a District Attorney’s Office, the New York 

State or City Police, or any other investigative or law enforcement agency? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 34. Have you, any member of your family, or any close friend ever been a party, 

appeared as a witness, or otherwise been involved in any trial or court 

proceeding, or any investigation by a federal or state grand jury or by a 

congressional or state legislative committee, licensing authority, or 

governmental agency? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Sabir: Jury Questionnaire

12

35. Have you or your business, any member of your family, or any close friend

ever been a party to or had an interest in the outcome of an investigation, or 

a legal dispute with the United States, or any agency of the United States, 

including the IRS? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 36. Have you, any member of your family, or any close friend ever been a 

victim of a crime, or appeared as a witness or a complainant in any criminal 

case or investigation, under state or federal law? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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13

37. Have you, or has any member of your family or a close friend, ever been 

employed by or received training by any local, state, or federal law 

enforcement agency, including but not limited to the following? (Circle as 

many as apply for each category.) Close Self Relative Friend

Federal Bureau of X X X 

Investigation

U.S. Attorney X X X 

Bureau of Alcohol, Tobacco, X X X 

Firearms & Explosives

U.S. Citizenship and

Immigration Services, and

Bureau of Immigration and X X X 

Customs Enforcement (formerly

known as Immigration and

Naturalization Services) Department of Homeland X X X 

Security

Drug Enforcement X X X 

Administration

Military Police X X X 

Department of Corrections X X X 

State Troopers X X X 

Office of District Attorney X X X 

United States Marshals X X X 

Service

New York City Police X X X 

Department

U.S. Bureau of Prisons X X X 

Department of Probation X X X 

and Parole

Other: ____________________ X X X 

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United States v. Sabir: Jury Questionnaire

14

38. Have you or any member of your immediate family ever served in the 

military (including the National Guard and the military reserves)? _____ Yes _____ No

Please describe the nature of any such military service by you or any 

member of your immediate family, including the dates of service, branch of 

the military, rank, and duties. ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 39. What civic, social, union, professional, fraternal, political, recreational, or 

religious organizations have you belonged to or participated in? Please 

indicate if you’ve held an office in any of those groups. ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 40. Do you know anyone who presently resides in the Middle East? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 41. Have you, or has a family member or friend, been the victim of terrorism, 

either in this country or abroad? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 42. Have you ever experienced what you believed to be discrimination against 

you because of your religious beliefs, national origin, race, or other factors? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Sabir: Jury Questionnaire

15

43. Please rate your knowledge of Islam on a scale of 1 through 5, where 5 = 

very knowledgeable about the faith of Islam and 1 = no knowledge of Islam. Choose a number: __________

44. Is there anything about a case in which the defendant is Muslim that would 

make it hard for you to serve fairly and impartially as a juror? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 45. What are your primary sources of local and national news? ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 46. Do you ever listen to political commentators on TV or “talk radio”? _____ Yes _____ No

If yes, what stations and shows do you listen to? _____________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 47. What television programs, if any, do you watch regularly? ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Sabir: Jury Questionnaire

16

48. Have you ever served as a juror? _____ Yes _____ No

If yes, please complete as appropriate:

_____ Civil Date(s): ____________________________________ Nature of case(s): ____________________________ Federal or state case(s): _______________________ Was the jury asked to reach a verdict? _____ Yes _____ No If so, was a verdict reached? _____ Yes _____ No

_____ Criminal Date(s): ____________________________________ Nature of case(s): ____________________________ Federal or state case(s): _______________________ Was the jury asked to reach a verdict? _____ Yes _____ No If so, was a verdict reached? _____ Yes _____ No

_____Grand Jury Date(s): ____________________________________ Nature of case(s): ____________________________ Federal or state case(s): _______________________ If yes, was there anything about your jury experience that would make it 

difficult to serve again fairly and impartially? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Sabir: Jury Questionnaire

17

49. Do you speak Arabic (or any dialect of Arabic)? _____ Yes _____ No

If yes, please explain how and where you learned the language. ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 50. Have you worked in or traveled in Saudi Arabia? _____ Yes _____ No

If yes, please explain how long you were there and the reason for your visit. ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 51. The witnesses in this case will include law enforcement personnel. Would 

you be inclined to believe a witness either more or less solely by reason of 

the witness being a federal agent or a police or law enforcement officer? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 52. The United States has the burden of proving its case beyond a reasonable 

doubt. This burden never shifts to the defendant. He is presumed innocent 

and cannot be convicted unless the jury, unanimously and based solely on 

the evidence presented in court, decides that his guilt has been proved 

beyond a reasonable doubt. Would you have any difficulty following this 

rule where the allegations against the defendant include material support of 

terrorism? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Sabir: Jury Questionnaire

18

53. Under our system of law, the facts are for the jury to determine and the law 

is for the Court. These two areas are separate and distinct. At the end of the 

case the Court will instruct you on the law. You are required to accept the 

law as the Court explains it to you. It will be your job to determine the facts 

under the Court’s explanation of the law. Would you be willing and able to 

apply the law as the Court explains it to you? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 54. The law provides that only the evidence produced here in court may be 

considered by you to determine the guilt or innocence of the defendant.

Would you accept and follow that law? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 55. It is not a particularly pleasant duty to find another individual guilty of 

committing a crime. Do you feel that, even if the evidence established the 

defendant’s guilt beyond a reasonable doubt, you might not be able to render 

a guilty verdict for reasons unrelated to the law and the evidence? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 56. Do you have any religious, philosophical, or other beliefs that might make 

you unable to render a guilty verdict even if the evidence established the 

defendant’s guilt beyond a reasonable doubt for reasons unrelated to the law 

and the evidence? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 

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United States v. Sabir: Jury Questionnaire

19

57. Will you accept the proposition of law that the question of punishment is for 

the Court alone to decide and that possible punishment must not enter into 

the deliberation of the jurors as to the guilt or innocence of the defendant? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 58. A defendant is not required to call any witnesses, produce any evidence, or 

take the stand. If the defendant elects not to take the stand, you may draw no 

unfavorable inferences of any kind from the fact that he has not done so.

That may not enter into your decision in any way. Will you accept and 

follow that instruction? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________ 59. This questionnaire has tried to direct your attention to possible reasons why 

you might not be able to sit as a fair and impartial juror. Apart from any 

prior question, is there any fact, circumstance, opinion, impression, attitude 

of mind, personal or other experience, or identification or membership with 

any group or organization that would prevent you, if you are accepted as a 

juror in the trial of this case, from listening to the evidence with an open 

mind and deciding every issue fairly and impartially, solely and only upon 

the evidence as heard from the witnesses and the Court’s instructions as to 

the law? _____ Yes _____ No

If yes, please explain: __________________________________________ ____________________________________________________________ ____________________________________________________________

____________________________________________________________

____________________________________________________________

____________________________________________________________

____________________________________________________________

____________________________________________________________

____________________________________________________________

____________________________________________________________ 

184 184
United States v. Sabir: Jury Questionnaire

20

Attachment A

Taisha Abdel Aziz

Mustafa AlMutazzim

Special Agent Manuel Aponte- Davilla

Joy Belnavis

Terence Bland, a/k/a “Siddique”

Mahmud Faruq Brent, a/k/a 

Mahmud AlMutazzim

Kevin Brown, a/k/a “Yasin”

Seifullah Chapman

Dr. Jean DeLaMothe

Ronald Drayton

Ibrahim Dremali

Faheem Abdur Elrazzaaq

Joseph Enright

Abdulrahman Farhane

Special Agent Robert Fuller

Wesley Grant

Special Agent Affell Grier, Jr.

Paul Hamilton

Nehemiah Head, a/k/a “Khalil”

Dr. Hope Hill

Dr. Samuel Jackson

Dr. Faroque Khan

Clifton Kearney, a/k/a “Anwar 

Kearney”

Evan Kohlmann

Cyclin Lewis

Special Agent Maria Lompart

Daniel McBride

Yahya Muhammad, a/k/a “Carl 

Taylor,” a/k/a “Abu Ubaidayh”

Hassan Abdel Mumin

Joyce Muschette

Ibrahim Najm

Samuel Nelson, a/k/a “Umar”

Mario Novak

Dr. Comenius Palaganos

Bilal Phillips

Special Agent Ryan Plunkett

Anthony Richardson

Special Agent Trenton Schmatz

Tarik Shah

Zakkiyah Shah

Hassan Sharif

Ali Soufan

Ali Al-Timimi

James Abdullah Wajid

Detective John White

Mohammed Yacoubi

Michael Yetter

185
21

Explanation Sheet ________________________________________________________________ ________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________ 

186 186
1 

United States v. Moussaoui: 

Preliminary Venire Instructions 

Hon. Leonie M. Brinkema

Eastern District of Virginia 

February 6, 2006 

The following text was prepared by the Eastern District of Virginia’s United 

States District Judge Leonie M. Brinkema to address prospective jurors selected 

for the penalty phase of a capital prosecution for conspiracy with perpetrators of 

the September 11, 2001, attacks on New York and Washington, in United States 

v. Moussaoui, No. 1:01-cr-455 (E.D. Va. Dec. 11, 2001). The defendant pleaded 

guilty. 

Opening Instructions to the Prospective Jurors 

Ladies and gentlemen, thank you for appearing this morning (afternoon). You 

have been summoned here to be considered for jury duty in the case of United 

States of America v. Zacarias Moussaoui, a/k/a “Shaqil,” a/k/a “Abu Khalid al 

Sahrawi,” who on April 22, 2005, pleaded guilty to three conspiracies at issue in 

this trial: 

(1) conspiracy to commit acts of terrorism transcending national boundaries; 

(2) conspiracy to destroy aircraft; and (3) conspiracy to use weapons of mass destruction in connection with the September 11, 2001, attacks in New York and 

Northern Virginia and the hijacking of four aircraft and their crashes in New 

York, Pennsylvania, and Virginia. Each of these convictions exposes him to a 

possible sentence of death. 

It will be the duty of the jury whose selection begins today to decide whether 

Mr. Moussaoui should be sentenced to death or be sentenced to life imprisonment without possibility of release. Based on Mr. Moussaoui’s guilty pleas, there 

are no other sentences possible for those three conspiracies. Obviously, deciding 

whether to recommend a sentence of death is the most serious decision that a jury 

is ever called upon to make in a legal system. The gravity of this decision is reflected in the multi-step process set out in the Federal Death Penalty Statute. 

Just because a person is guilty of a capital crime, that is a crime for which 

death is a possible penalty, does not mean that person should be sentenced to 

death. Instead, the jury must make specific factual findings about the defendant 

and what he specifically did in order to impose a death penalty. In this case, the 

first finding is whether the defendant’s specific intentional conduct makes him 

death eligible. More precisely, the jury will be asked to decide whether the defendant intentionally participated in an act, which the government argues was his 

lying to agents after his arrest on August 16, 2001, which directly resulted in the 

deaths that occurred during the airplane hijackings and crashes on September 11, 

2001. 

If the jury were to find that Mr. Moussaoui did intentionally do such an act 

and that those deaths were a direct result of that act, the second phase of the trial 

would involve the presentation and consideration of evidence of aggravating and 

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United States v. Moussaoui: Preliminary Venire Instructions 

2 

mitigating factors and the question of whether Mr. Moussaoui should be sentenced either to life imprisonment without the possibility of release or death. Aggravating factors are facts about the defendant or the crime that the government 

believes favor the death penalty. Aggravating factors are of two types: statutory 

reasons, which are set forth in the death penalty statute, and non-statutory, other 

reasons, which are drafted by the government. Mitigating factors are facts about 

the circumstances of the crime or the defendant’s role in it, or about his background or character, that the defense believes favor a sentence of life imprisonment without possibility of release. 

In determining the appropriate punishment, each juror will have to consider 

the aggravating factors that had been proved beyond a reasonable doubt and any 

mitigating factors that the juror believes exist before making a determination as 

to the appropriate punishment. The jury itself does not actually impose the final 

sentence. That will be the Court’s responsibility, but it must impose the sentence 

found appropriate by the jury. 

This is only an overview of the law applicable to the jury’s consideration of 

the death penalty. The jury will receive much more detailed instructions from the 

Court during the course of the proceedings. 

Because this case will involve evidence about al-Qaeda and the September 

11 attacks on the World Trade Center and the Pentagon, the case has received a 

great deal of publicity over the past few years. I assume every one of you is 

aware of what happened on September 11, has watched or read extensive media 

coverage about that day, and has watched news reports or read about al-Qaeda. 

And I expect many if not all of you have heard or read something about this case 

and the defendant. Such media exposure does not necessarily disqualify you from 

being eligible to serve on the jury, but it is obviously an issue we need to probe 

carefully. The problem with pretrial exposure to information about a defendant or 

issues in a case is simply this: Persons on trial must be judged not on the basis of 

what is in the news or popular media, but rather on the hard evidence presented 

in the courtroom during the trial. 

If the pretrial publicity to which you have been exposed has caused you to 

form such strong opinions about the defendant or issues in the case that you think 

you might not be able to put those opinions aside entirely and listen to and evaluate the trial evidence with an open mind, then you must so advise the Court on 

the Jury Questionnaire that I will soon describe. 

Similarly, the death penalty is a very controversial issue about which many 

Americans hold strong views. Simply having thought about or listened to or read 

about the death penalty will not disqualify you from being a juror in this case 

unless your views are so firmly set as to make it difficult for you to evaluate this 

case on the evidence presented during the trial and apply the law given to you by 

the Court, even if you disagree with that law. 

To help the lawyers and the Court select a jury that can objectively listen to 

the evidence and decide the case solely on the basis of the evidence produced in 

this courtroom during the trial and within the law as the Court explains it, we 

have prepared a Jury Questionnaire, which you will be asked to fill out. Your 

totally candid answers to the questions in the questionnaire are essential to the 

government and Mr. Moussaoui’s receiving a fair sentencing hearing. To ensure 

188 188
United States v. Moussaoui: Preliminary Venire Instructions 

3 

that you feel comfortable answering these questions honestly, I have determined 

that your identities will not be revealed to any trial participant or to the public. In 

other words, you will be an anonymous jury. Only limited members of the court 

staff know your names. That is why you have been given a four-digit number as 

your identifier. 

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. Your 

cooperation is of vital importance. Please answer each question as fully and 

completely as possible. Your complete candor and honesty is necessary so that 

both the prosecution and the defense will have a meaningful opportunity to select 

an impartial jury. 

You must answer all the questions, to the best of your ability. If you do not 

know the answer to a question, write, “I don’t know.” If the question does not 

apply to you, write “N/A.” If you do not understand a question, just write “don’t 

understand.” Do not ask court personnel to explain the question. They are not 

permitted to do that. DO NOT LEAVE ANY QUESTION BLANK. It is important that the answers be yours alone. If you need more space for your responses 

or wish to make further comments regarding any of your answers, please use the 

Explanation Sheet at the end of the questionnaire. Put the number of the question 

you are answering on the Explanation Sheet before you write the response or 

comment. 

Please keep in mind that there are no “right” or “wrong” answers, only complete and incomplete answers. Complete answers are far more helpful than incomplete answers. Remember, you are sworn to give true and complete answers 

to all questions. 

Unless the question states otherwise, the fact that a particular question is 

asked does not imply that the subject matter of the question is an issue in this 

case. As you read the questions, you are not to draw any inferences about the issues that must be decided in this case. Do not write on the back of any page. 

PLEASE PRINT OR WRITE LEGIBLY, and be sure to put your juror 

number on the upper right corner on each page. When you have finished 

answering the Questionnaire, you must sign with your name. In that signature page you are affirming the accuracy of your answers. That page will be 

removed by court staff and will not be shown to any party. 

Part of the questionnaire includes a list of all persons who may be called as 

witnesses to testify. You must put your juror number on that witness list and return it to the court staff with your questionnaire. You may not disclose the name 

of any of those witnesses to anyone. The court personnel will advise you when 

you may leave once they have collected your questionnaire and the witness list 

from you. 

After you complete the questionnaire, the next step will be for some of you to 

return to the courthouse for more specific individual questioning by the Court. 

The first of these individual questioning sessions begins Wednesday, February 

15, 2006, so you are all free to go to work or otherwise keep your normal schedule until your next time to report. Individual questioning will continue daily until 

approximately 85 jurors are found eligible. To find out whether you have to re189
United States v. Moussaoui: Preliminary Venire Instructions 

4 

turn for individual questioning, and if so, when, you must call the jury information number given to you by the court’s staff. If you are asked to return for individual questioning, you should expect to be at the courthouse for up to four 

hours. You will have to report either for a morning session starting at 9:30 a.m. 

or an afternoon session starting at 2:00 p.m. Immediately after the questioning 

session, you will be told whether you have been excused or need to return for the 

final round of jury selection, which is scheduled to start at 10:00 a.m. on Monday, March 6, 2006, in courtroom 700. 

On March 6, 2006, 18 of you will ultimately be chosen to hear this case, although only 12 of you will actually deliberate and issue the final decision. The 

other 6 are alternates. We use alternates in long trials to be sure that if someone 

gets sick or for some other reason cannot continue as a juror we are sure to have 

the 12 jurors the law requires to make the decision at issue in this trial. No one is 

designated an alternate until just before deliberations begin. 

If you are selected on March 6 to be one of the 18 jurors, you will need to 

remain at the courthouse all day, because we expect opening statements and 

some witness testimony to start Monday afternoon. Lunch will be provided for 

you, so do not worry about bringing food unless you have special food needs. 

After March 6, the trial will be held from 9:30 a.m. to 5:30 p.m. Monday 

through Thursday. If we stay on schedule, we will not hold court on Fridays until 

the jury begins its deliberations. I will try to give you several days’ notice if we 

plan to hold court on Fridays. Each phase of this trial is expected to last several 

weeks, which is why you were initially advised that the trial could go into late 

May. However, I will have a better time estimate for you after the trial begins. 

Obviously, we need jurors who can serve for the entire trial. 

From today on, until you are notified that you have been excused from this 

case, you must avoid reading, listening to, or in any other respect being exposed 

to anything about this case, the attacks on September 11, or the death penalty. 

You may not investigate any of the facts related to this case, or view the court’s 

website for this case. You are not to discuss or communicate about this case or 

any of the above issues with anyone. I have issued an Order that prohibits anyone, including members of the media and the general public, from trying to contact, interview, identify, or in anyway communicate with potential jurors. If you 

believe someone has tried to do so, call the Court immediately. 

Lastly, the duty some of you will be asked to perform—to sit in judgment of 

another human being and decide whether he should live or die—is an awesome 

responsibility not to be taken lightly. You must have the moral integrity to follow 

the law, even if you disagree with it, and you must find the facts fairly, even if 

you do not personally like the conclusion to which they lead. You must be able to 

withstand any bias, prejudice, or sympathy for either side of this case, and any 

public opinion. You must agree that your only goal as a juror in this case is to 

reach a fair and just decision. That is what our legal system expects of its jurors, 

and that is what this Court expects from you. 

Once again, thank you for appearing today. The Court will now stand in recess. 

190 190
1 

United States v. Moussaoui: 

Jury Questionnaire 

Hon. Leonie M. Brinkema

Eastern District of Virginia 

February 6, 2006 

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. Moussaoui, No. 1:01-cr-455 (E.D. 

Va. Dec. 11, 2001). 

General Instructions 

This questionnaire is designed to obtain information about your background as it 

is related to your service as a juror in this case. Its use will substantially shorten 

the jury selection process. The purpose of these questions is to determine whether 

prospective jurors can impartially decide this case based upon the evidence presented at trial and the instructions on the law given by the presiding judge. The 

questions are not intended to unnecessarily inquire into personal matters. All information contained in this questionnaire will be kept confidential and under seal. 

You are sworn to give true and complete answers and those answers will be 

available only to the court and the parties in this case. The questionnaires belong 

to the court and all copies will be returned to the court. You are instructed not to 

discuss this case or the questionnaire with anyone, including your family and fellow jurors and members ofthe media. 

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. Your 

cooperation is of vital importance. Please answer each question as fully and 

completely as possible. Your complete candor and honesty is necessary so that 

both the prosecution and the defense will have a meaningful opportunity to select 

an impartial jury. 

You must answer all the questions, to the best of your ability. If you do not 

know the answer to a question then write, “I don't know.” If the question does not 

apply to you, write “N/A.” Please fill out the entire questionnaire. DO NOT 

LEAVE ANY QUESTION BLANK. It is important that the answers be yours 

alone. If you need more space for your responses or wish to make further comments regarding any ofyour answers, please use the Explanation Sheet at the end 

of the questionnaire. Put the number ofthe question you are answering on the Explanation Sheet before you write the response or comment. 

Please keep in mind that there are no “right” or “wrong” answers, only complete and incomplete answers. Complete answers are far more helpful than incomplete answers. Remember, you are sworn to give true and complete answers 

to all questions. 

Unless the question states otherwise, the fact that a particular question is 

asked does not imply that the subject matter of the question is an issue in this 

191
United States v. Moussaoui: Jury Questionnaire 

Juror No. __________ 

2 

case. As you read the questions, you are not to draw any inferences about the issues which must be decided in this case. Do not write on the back of any page. 

PLEASE PRINT OR WRITE LEGIBLY, and be sure to put your juror 

number on each page. When you have finished answering the Questionnaire, 

you must sign with your name. In that signature page you are affirming the 

accuracy of your answers. That page will be removed by court staff and will 

not be shown to any party. 

Personal Background 

Juror’s Number: ___________________________________________________ 

1. Gender: ____________ 

2. Age: ____________ 

3. Place of Birth: _________________________________________________ 

4. What is your ethnic background? 

_____ White/Caucasian, not Hispanic 

_____ Black/African-American, not Hispanic 

_____ Hispanic/Latino 

_____ Asian or South Asian 

_____ American Indian or Native American 

_____ Other: __________________________________________________ 

 (please specify) 

5. In what town, city, or county do you currently live? ___________________ 

6. Length of time at current address: ________________ 

7. How long have you lived in Northern Virginia? ________________ 

8. If you have lived less than five years at your current address, indicate your 

prior town or community. 

 _____________________________________________________________ 

9. What is your current marital/domestic status? (Check all that apply.) 

________ Single/Never married ________ Divorced 

________ Married _____ years ________ Divorced and remarried 

________ Domestic partner ________ Widowed 

________ Separated ________ Lives with others 

192 192
United States v. Moussaoui: Jury Questionnaire 

Juror No. __________ 

3 

10. If you have children or stepchildren, please list them. 

 Sex Age Live with you? Education level Occupation 

1. 

2. 

3. 

4. 

5. 

11. Do you read, speak, write, and understand English? 

_____ Yes, without difficulty 

_____ Yes, with difficulty 

_____ No 

12. Do you speak, read, or understand French? If so, how well? 

 _____________________________________________________________ 

13. In what country were your parents born? 

Mother: ___________________________ __________________________ 

Father: ____________________________ 

14. What is/was your father’s occupation? 

 _____________________________________________________________ 

15. What is/was your mother’s occupation? 

 _____________________________________________________________ 

16. Are you, your spouse (domestic partner), or a former spouse (domestic partner), parents, in-laws, or grandparents naturalized U.S. citizens? 

 Yes ____ No ____ 

 If yes, please indicate the status of the person, i.e., “spouse,” and tell us 

when the person became a citizen. 

 _____________________________________________________________ 

193
United States v. Moussaoui: Jury Questionnaire 

Juror No. __________ 

4 

17. Do you speak, read, or understand Arabic (or any dialect of Arabic), or did 

you grow up in a household where that language or any of its dialects was 

spoken? 

 Yes ____ No ____ 

(a) Do you read any Arabic-language newspapers or publications? 

Yes ____ No ____ 

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

(b) Do you watch any Arabic-language television programs, including 

newscasts? 

Yes ____ No ____ 

If so, please list these programs/newscasts.

(c) If you speak, read, or understand the Arabic language (or any of its dialects), would you have any difficulty relying solely upon the official 

interpreter’s translation of testimony and witnesses’ translations of the 

evidence? 

Yes ____ No ____ 

18. Have you, any family member, or a close personal friend ever traveled to, 

lived in, or worked in, either in a civilian or a military capacity, any of the 

following countries? 

Morocco Afghanistan Saudi Arabia Qatar Yemen 

Algeria Egypt Indonesia Malaysia Jordan 

Iraq Pakistan Turkey Iran Israel 

Tunisia Syria Sudan Palestine Libya 

United Arab Emirates (UAE) 

 Yes No (If yes, please circle the appropriate countries.) 

19. What is your occupational status? (Check all that apply.) 

_____ Work full-time outside the home _____ Student 

_____ Work part-time outside the home _____ Retired 

_____ Full-time homemaker _____ Disabled 

_____ Homemaker with part-time employment _____ Other: ___________ 

_____ Unemployed ______________________ 

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United States v. Moussaoui: Jury Questionnaire 

Juror No. __________ 

5 

20. Without giving your place of employment, please state your current occupation. 

 _____________________________________________________________ 

21. Check the following category that best describes your employer. 

____ Federal government agency ____ Private, for-profit corporation 

____ State government agency ____ Private, not-for-profit organization 

____ County government agency ____ Self employed 

____ City government agency ____ Other: _______________________ 

22. Describe what you do. __________________________________________ 

 _____________________________________________________________ 

 How long have you held this job? _________________________________ 

23. Please list all prior occupations or jobs during the past 15 years. 

Occupation Length of Employment 

 

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

you work for one? 

 Yes ____ No ____ 

 If yes, please describe. 

25. What is your spouse or domestic partner’s occupational status? (Check all 

that apply.) 

_____ Work full-time outside the home _____ Student 

_____ Work part-time outside the home _____ Retired 

_____ Full-time homemaker _____ Disabled 

_____ Homemaker with part-time employment _____ Other: ___________ 

_____ Unemployed ______________________ 

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United States v. Moussaoui: Jury Questionnaire 

Juror No. __________ 

6 

26. Check the following category that best describes your spouse or domestic 

partner’s employer. 

____ Federal government agency ____ Private, for-profit corporation 

____ State government agency ____ Private, not-for-profit organization 

____ County government agency ____ Self employed 

____ City government agency ____ Other: _______________________ 

27. Without giving the place of employment, what is your spouse or domestic 

partner’s current occupation or job title? 

 _____________________________________________________________ 

 _____________________________________________________________ 

28. What kind of work did he or she do in the past? ______________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

29. Check the highest level of education for you and your spouse or domestic 

partner. 

 Spouse or 

 You domestic partner 

(a) Grade school or less ______ 

(b) Some high school ______ 

(c) High school graduate ______ 

(d) Technical or business school ______ 

(e) Some college ______ 

(f) College degree ______ 

(g) Graduate work or degree ______ 

 If you attended college or received a graduate degree, identify all colleges 

and graduate schools you attended. 

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United States v. Moussaoui: Jury Questionnaire 

Juror No. __________ 

7 

30. Do you, your spouse or domestic partner, or another member of your immediate family have any education, training, or employment experience in any 

of the following fields? 

 Yes No Some 

(a) Accounting, auditing, bookkeeping ______ ______ ______ 

(b) Aircraft, airline industry, aviation ______ ______ ______ 

(c) Security, intelligence ______ ______ ______ 

(d) Private investigations ______ ______ ______ 

(e) Law ______ ______ ______ 

(f) Medicine ______ ______ ______ 

(g) Psychology, psychiatry, or social work ______ ______ ______ 

(h) Corrections (work in prisons/jails) ______ ______ ______ 

(i) Religion and/or philosophy ______ ______ ______ 

(j) Criminal justice ______ ______ ______ 

(k) Foreign languages ______ ______ ______ 

(l) Journalism, media, communications ______ ______ ______ 

(m) Emergency rescue, firefighting, EMT ______ ______ ______ 

(n) Computer or information technology ______ ______ ______ 

 If yes, please explain the nature and extent of the education, training, or employment experience. ___________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

31. Have you ever worked as a volunteer firefighter or as a member of a rescue 

squad or abulance crew for any federal, state, or local agency? 

 Yes ____ No ____ 

(a) If yes, describe the nature of your service. _______________________ 

 _________________________________________________________ 

(b) If yes, during what time period(s)? _____________________________ 

 _________________________________________________________ 

32. Have you ever worked as a commercial pilot? 

 Yes ____ No ____ 

 If yes, during what time period and for what airline? 

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33. Have you ever taken any training to become a pilot? 

 Yes ____ No ____ 

 Ifyes, please describe the training that you had and the time period when 

you took the training, and please identify the school where you took the 

training. 

34. Have you ever attempted to obtain a pilot’s license? 

 Yes ____ No ____ 

 If yes, answer the following questions. 

When? ____________________________ 

Where? ____________________________ __________________________ 

Did you obtain the license? Yes _____ No ____ 

35. Have either you or your spouse or domestic partner worked in an airport? 

 Yes ____ No ____ 

(a) If yes, was it you or your spouse or domestic partner? ______________ 

(b) If yes, please provide the time period when you or your spouse or domestic partner worked at the airport and describe the nature of the 

work. 

36. How often do you fly on airplanes? (Check the most appropriate answer.) 

 Never _______ Seldom _______ Often _______ 

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Military Service 

37. Have you, your spouse or partner, or an immediate family member ever 

served in the armed forces, including the reserves, National Guard, or 

ROTC? 

 Yes ____ No ____ 

 If yes, please answer the following.

 Spouse or Family 

 You Partner Member 

(a) Branch and highest rank _______ _______ ________ 

(b) Dates of service _______ _______ ________ 

(c) Place of service _______ _______ ________ 

(d) Type of discharge _______ _______ ________ 

(e) Served at the Pentagon? _______ _______ ________ 

(f) Dates at the Pentagon _______ _______ ________ 

(g) Any experience with courts 

martial, military police, shore 

patrol, or other area of military 

law enforcement? _______ _______ ________ 

(h) Did you or they have any 

combat experience? _______ _______ ________ 

 If so, identify the location and years. _______________________________ 

 _________________________________________________________ 

 _________________________________________________________ 

38. (a) Since September 11, 2001, have you, a family member, or a close 

friend served in or been injured while serving in a combat or military 

zone in Iraq, Afghanistan, or elsewhere in the Middle East? 

Yes ____ No ____ 

If yes, please explain. _______________________________________ 

 _________________________________________________________ 

 _________________________________________________________ 

(b) Since September 11, 2001, has any family member or close friend been 

killed while serving or working in a military or combat zone in Iraq, 

Afghanistan, or elsewhere in the Middle East? 

Yes ____ No ____ 

If yes, please explain. _______________________________________ 

 _________________________________________________________ 

 _________________________________________________________ 

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Organizational Affiliations, Hobbies, and Spare Time Activities 

39. Please list organizations to which you or your spouse or domestic partner 

belong or in which either of your participate, either now or in the past five 

years. (Include any civic, social, religious, charitable, volunteer, political, 

sporting, professional, business, union, fraternal, and recreational groups, 

such as, but not limited to, Kiwanis, Rotary Club, Exchange Club, Knights 

of Columbus, Veterans of Foreign Wars, American Legion, American Civil 

Liberties Union, National Rifle Association, and League of Women Voters.) 

 Self: _________________________________________________________ 

 _____________________________________________________________ 

 Spouse or domestic partner: ______________________________________ 

 _____________________________________________________________ 

40. Have you ever held any office or title in any of the organizations you listed 

in question 30? 

 Yes ____ No ____ 

41. To what groups or organizations, including any victims rights or disaster 

relief organizations, if any, didyou donate money, goods, or volunteer time 

during the last five years? ________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

42. 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. 

43. Would you say that you seek out positions of leadership when you participate with others in your employment or other activities 

 Always ____ Often ____ Sometimes ____ Seldom ____ Never ____ 

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Media Consumption 

44. (a) How often do you read a newspaper? 

____ Every day 

____ Several times a week 

____ Once or twice a week 

____ Less often than once a week 

____ Never 

 (b) How often do you watch TV news? 

____ Every day 

____ Several times a week 

____ Once or twice a week 

____ Less often than once a week 

____ Never 

 (c) How often do you listen to radio news? 

____ Every day 

____ Several times a week 

____ Once or twice a week 

____ Less often than once a week 

____ Never 

 (d) How often do you get news off the Internet? 

____ Every day 

____ Several times a week 

____ Once or twice a week 

____ Less often than once a week 

____ Never 

 Please list all sources of news you watch, listen to, or read on a regular basis, in print or on television, radio, or the Internet, including the names of 

any particular news programs or Internet sites. Include radio talk shows. 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

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45. Do you ever listen to radio talk shows, turn to political commentators on TV 

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

 Yes ____ No ____ 

 If yes, which one(s)? 

46. If you are chosen to be a juror, you will not be permitted to read or listen to 

any media or Internet coverage of this case and related subjects. Would 

these restrictions pose any difficulty for you? 

 Yes ____ No ____ 

 If yes, please explain. 

Contact and Experiences with Crime, Courts, and the Legal System 

47. Are you, or is any close friend or relative, a member of a neighborhood 

crime watch or prevention group? 

 Yes ____ No ____ 

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

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48. Have you, or has any member of your family or a close friend or relative, 

ever been the victim of or witness to a crime, whether or not that crime was 

reported to law enforcement authorities? 

 Yes ____ No ____ 

(a) If no, go to the next numbered question. If yes, please provide the following information for each person and incident. 

Relationship 

(self, sister, 

etc.) 

Type of 

Crime 

Victim or 

Witness 

Reported 

to Police? 

Was 

Anyone 

Caught? 

Outcome 

of the 

Case 

 

 

(b) In what ways, if any, did any of these incidents that you, or a person 

close to you, experienced affect your attitude about crime? 

(c) How do you feel about how the police or law enforcement authorities 

handled the situation? 

49. Have you or has any family member or close friend had any personal experience with acts of terrorism? 

 Yes ____ No ____ 

 If yes, please explain. 

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50. Have you, or has any member of your family or a close friend, ever been 

questioned about, accused of, investigated for, arrested for, or charged with 

a crime, other than a minor traffic offense? 

 Yes ____ No ____ 

(a) If yes, please provide the following: 

Relationship of Person 

Charged (self, sister, etc.) Crime(s) Charged Case Outcome 

 

 

(b) If yes, please provide a brief description of the alleged crime or crimes 

and the events leading up to the accusation, arrest, or charge. 

(c) How did you feel about being questioned about that experience? 

 (d) Would this experience affect your ability to serve as a juror in this 

case? 

Yes ____ No ____ 

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 state when, and explain why you appeared in court. 

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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 state when, and explain why you appeared in court. 

52. Have you ever had an unfavorable experience with a lawyer or judge? 

 Yes ____ No ____ 

 If yes, please explain. 

53. Have you, or has any close friend or relative, made or brought any claim or 

lawsuit against any federal, state, or local government agency? 

 Yes ____ No ____ 

 If yes, please explain. 

54. Have any claims or lawsuits ever been made by any federal, state, or local 

official or government agency against you or any close friend or relative? 

 Yes ____ No ____ 

 If yes, please explain. 

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55. Have you ever served as a juror at a trial before? 

 Yes ____ No ____ 

(a) If yes, please complete the following for each trial on which you served 

as a juror 

When Did 

You Serve? 

In What 

Court? 

Criminal or 

Civil? 

Charges/ 

Allegations 

What 

Verdict Did 

the Jury 

Reach? 

1. 

2. 

3.

(b) Have you ever served as a jury foreperson? 

Yes ____ No ____ 

 (c) Was there anything about your jury experience that left you disappointed or dissatisfied with our justice system? 

Yes ____ No ____ 

Please explain. ____________________________________________ 

 _________________________________________________________ 

 _________________________________________________________ 

 (d) Was there anything about your experience as a juror which would make 

you not want to serve again? 

Yes ____ No ____ 

Please explain. ____________________________________________ 

 _________________________________________________________ 

 _________________________________________________________ 

(e) In general, how much did you participate in that jury’s discussion? 

 Less than other jurors 

 About the same 

 More than other jurors 

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

around? 

 Yes ____ No ____ Unsure ____ 

 If yes, please explain. 

57. Do you know of any reason that would keep you from serving fairly and 

impartially as a juror in a case in which the defendant was a person whose 

race was different from yours? 

 Yes ____ No ____ 

 If yes, please explain. 

58. Do you generally “hold your ground” when you feel that you are correct, or 

are you easily swayed by the strong influence of others? 

 Always hold my ground 

 Generally hold my ground 

 Generally swayed by others 

 Almost always swayed by others 

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59. Have you, any member of your family, or any close friend ever been employed by or made an application for employment with any local, state, or 

federal law enforcement or private security agency or international aid organization, including, but not limited to, the following? (Check as many as 

apply for each category.) 

 Self 

Family 

Member 

Close 

Friend Position 

Federal Bureau of 

Investigation (FBI) 

 

U.S. Attorney’s Office 

State Prosecutor’s Office 

Internal Revenue Service 

(IRS) 

 

Drug Enforcement Agency 

(DEA) 

 

Central Intelligence Agency 

(CIA) 

 

National Security Agency 

(NSA) 

 

Department of Justice 

State Department 

Any U.S. Embassy 

U.S. Treasury Department 

Department of Homeland 

Security 

 

Peace Corps 

Agency for International 

Development (AID) 

 

Immigration and 

Naturalization Service 

(INS) 

 

Military Police 

Correctional Officer 

Bureau of Prisons 

Parole or Probation Office 

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 Self 

Family 

Member 

Close 

Friend Position 

State Police 

Police Department 

Sheriff’s Department 

U.S. Marshal’s Service 

Secret Service 

U.S. Customs 

U.S. Postal Service 

Federal Protective Services 

Naval Investigative 

Services 

 

Bureau of Alcohol, 

Tobacco, and Firearms 

(BATF) 

 

U.S. Park Police 

Other law enforcement or 

private security agency not 

listed (identify name of 

agency) 

 

60. Would you, as a juror, give law enforcement officers when testifying as a 

witness in a case, ore credibility, less credibility, or the same credibility as 

anyone else’s testimony? 

 More credibility 

 Less credibility 

 Same credibility 

 Please explain. 

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61. What, if any, opinion do you hold about the performance of the Federal Bureau of Investigation (FBI) in each of the following criminal investigations? 

Circle one response for each investigation.) 

Performed 

Well 

Performed 

Poorly 

Not 

Familiar 

with 

Matter 

No 

Opinion 

(a) Waco, TX 1 2 3 4 

(b) Ruby Ridge 1 2 3 4 

(c) Richard Jewell 1 2 3 4 

(d) Wen Ho Li 1 2 3 4 

(e) September 11th 1 2 3 4 

(f) Anthrax 1 2 3 4 

62. Have you, or has any close friend or relative, ever worked or been a volunteer in the legal profession either as a lawyer, paralegal, or in a law office, 

including a prosecutor’s or public defender’s office? 

 Yes ____ No ____ 

 If yes, please explain. 

63. Do you have any strong feelings about American intelligence services or 

foreign intelligence services? 

 Yes ____ No ____ 

 If yes, please explain. 

General Opinions and Beliefs about the Criminal Justice System 

Please check the answer that most closely reflects your own opinion concerning 

the following statements. 

64. Do you believe that punishment or rehabilitation is the more important objective in sentencing those convicted of violent crimes? 

 Punishment ____ Rehabilitation ____ 

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65. Do you believe that “proof beyond a reasonable doubt” is too heavy a burden for the prosecution to have to meet in a terrorism trial? 

 Yes ____ No ____ Unsure ____ 

66. Do you feel that the criminal justice system generally treats criminals too 

harshly, about right, or too leniently? 

 Too harshly ____ About right ____ Too leniently ____ 

67. Do you believe that defendants accused of participating in the terrorist acts 

of September 11th should be given the same rights as other criminal defendants? 

 Yes ____ No ____ Unsure ____ 

68. Do you believe that even in times of national crisis the rights of criminal 

defendants should be fully protected? 

 Yes ____ No ____ Unsure ____ 

69. Do you believe that “proof beyond a reasonable doubt” is too heavy a burden for the prosecution to meet in criminal trials? 

 Yes ____ No ____ Unsure ____ 

70. (a) The defendant, Zacarias Moussaoui, is not a citizen of the United 

States. Would you be able to afford him the same rights and considerations as you would a defendant who is a citizen of the United States? 

Yes ____ No ____ Unsure ____ 

Please explain. ____________________________________________ 

 _________________________________________________________ 

 _________________________________________________________ 

(b) The defendant has admitted to being a member of al Qaeda. Do you believe that you could be a fair and impartial juror in the trial of a member of that terrorist organization? 

Yes ____ No ____ Unsure ____ 

Please explain. ____________________________________________ 

 _________________________________________________________ 

 _________________________________________________________ 

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Mental Health Training and Experience 

71. Have you, anyone in your family, or a close personal friend ever received 

in-patient treatment, or been under a doctor’s care, or any type of mental or 

psychiatric condition, including mood disorders, or as treatment for alcoholism or drug abuse? 

 Yes ____ No ____ Unsure ____ 

 Please explain. 

Contact, Knowledge, and Experience with Religious Groups and 

Organizations 

72. What, if any, religion were you raised in? ___________________________ 

73. What is your current religious affiliation, if any? ______________________ 

74. How often do you attend religious services? 

 Regularly _____ Occasionally _____ Seldom _____ Never _____ 

75. How knowledgeable are you about the history and/or practices of Islam? 

_____ Very knowledgeable 

_____ Somewhat knowledgeable 

_____ Not too knowledgeable 

_____ Not knowledgeable at all 

76. Do you believe that Islam endorses violence to a greater or lesser extent than 

other major religions? 

 Yes ____ No ____ Unsure ____ 

 Please explain. 

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77. To the best of your knowledge, in what contexts have you had contact with 

people who follow the religion of Islam (Muslims) or are of Arab descent? 

(Please check all answers that apply.) 

_____ In the family 

_____ In the neighborhood 

_____ In organizations 

_____ Through work/business 

_____ In places of worship 

_____ In school 

_____ In everyday life (shopping, movies, etc.) 

_____ None 

_____ Other: __________________________________________________ 

78. Do you have any negative feelings or opinions about Muslims or people 

who are of Arab or North African descent? 

 Yes ____ No ____ 

 If yes, please explain. 

79. Is there anything about a case with a defendant or witnesses who are Muslim 

or of Arab descent that would make it hard for you to serve as a fair and impartial juror? 

 Yes ____ No ____ 

 If yes, please explain. 

Contact, Experience, and Knowledge of the Events of September 11, 2001 

80. Were you in the metropolitan Washington, D.C., or metropolitan New York 

City areas during the day of September 11, 2001? 

 Yes ____ No ____ 

81. Do you have any family members or friends who were in the metropolitan 

Washington, D.C., or metropolitan New York City areas during the day of 

September 11, 2001? 

 Yes ____ No ____ 

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82. Was anyone in your family or any close friend injured or killed in the attacks on the World Trade Center and the Pentagon or on the flight that was 

downed in Pennsylvania on September 11, 2001? 

 Yes ____ No ____ 

 If yes, please explain. 

83. Do you have a family member or close personal friend who knows someone 

who was injured or killed in the September 11 terrorist attacks or any of the 

victim’s family members or close personal friends? 

 Yes ____ No ____ Don’t know ____ 

 If yes, please explain. 

84. As a result of the terrorist attack, did you take any of the following actions 

on the day of September 11? 

(a) Leave the building you were in as a result of an 

evacuation order. Yes No 

(b) Choose to leave the building you were in. Yes No 

(c) Leave work early that day. Yes No 

(d) Call someone to check on their safety or to let 

them know of your safety. Yes No 

(e) Receive a call checking on your safety or the 

safety of others. Yes No 

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85. Do you know, or did you previously 

(a) Work at or near the Pentagon? Yes No 

(b) Live near the Pentagon? Yes No 

(c) Know someone who works at or near the 

Pentagon? Yes No 

(d) Know someone who lives at or near the 

Pentagon? Yes No 

(e) Work at or near the Twin Towers site in New 

York City? Yes No 

(f) Know someone who works at or near the Twin 

Towers site in New York City? Yes No 

(g) Know someone who lives at or near the Twin 

Towers site in New York City? Yes No 

(h) Participate in any way in any of the rescue 

efforts following the September 11th attack? Yes No 

(i) Know someone who participated in any way in 

any of the rescue efforts following the 

September 11th attack? Yes No 

(j) Know someone who has suffered emotional 

distress as a result of the September 11th 

attack? Yes No 

(k) Work in or near Somerset County, 

Pennsylvania? Yes No 

(l) Know someone who lives in or near Somerset 

County, Pennsylvania? Yes No 

(m) Know someone who works in or near Somerset 

County, Pennsylvania? Yes No 

 If yes, please explain. 

86. Did you drive by the Pentagon building in the days immediately following 

September 11, 2001, or during the period of the Pentagon’s reconstruction, 

to observe the damage? 

 Yes ____ No ____ 

 If yes, about how many times? __________ 

87. Have you been to the Pentagon building since September 11, 2001? 

 Yes ____ No ____ 

 If so, for what purpose? 

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88. Have you participated in any of the following activities in connection to the 

events of September 11th? 

(a) Donated money, goods, or time to support 

relief efforts for the victims of the 9/11 attacks. Yes No 

(b) Donated blood. Yes No 

(c) Visited the Pentagon crash site. Yes No 

(d) Visited the Twin Towers crash site in New 

York City. Yes No 

(e) Visited any memorial site or attended any 

memorial service for 9/11 victims and survivors. Yes No 

(f) Participated in the rebuilding of the Pentagon. Yes No 

(g) Displayed a flag or other patriotic symbol 

on your vehicle or home as a result of 

September 11th. Yes No 

(h) Purchased a magazine, book, or other item 

commemorating September 11th. Yes No 

(i) Contacted a Website concerning September 

11th related events. Yes No 

 Please explain. 

89. Have you ever attended any hearings (or portions of hearings) of the 9/11 

Commission or watched them on TV or listened to them on the radio? 

 Yes ____ No ____ 

90. Have you ever read any reports, memos, or documents written or reviewed 

by the 9/11 Commission, or read or heard portions or accounts of them in 

any newspaper or other news source? 

 Yes ____ No ____ 

 If yes to either question 89 or question 90, please describe. 

91. Do you know anyone who is a pilot or flight attendant or who works in any 

capacity for an airline, an airport, a travel agency, or any business that provides goods or services to the airline industry, or for governmental agencies 

that monitor or assist the airline industry? 

 Yes ____ No ____ 

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92. Did you or any family member or close personal friend have any plans to 

travel that were canceled as a result of the September 11th attacks? 

 Yes ____ No ____ 

93. Have you or any family member or close personal friend refused to fly in an 

airplane or been very reluctant to fly in an airplane as a result of the September 11th attacks? 

 Yes ____ No ____ 

94. Did you or any family member or close friend lose a job or a business contract or experience any other financial hardship as a result of events connected to September 11th? 

 Yes ____ No ____ 

95. Did you or any family member or close friend have to work substantial 

overtime or additional hours as a result of events connected to September 

11th? 

 Yes ____ No ____ 

96. How concerned are you that terrorists will commit acts of violence near 

where you live or work? 

 Very concerned ____ Somewhat concerned ____ Not concerned ____ 

97. How much, if any, have the events surrounding the September 11th attacks 

on the Pentagon or World Trade Center affected you personally? 

_____ A great deal 

_____ A good amount 

_____ Not too much 

_____ Not at all 

98. Have you written to any elected or appointed government official, or to any 

newspaper or magazine, or called in to any television or radio program, or 

written to any Internet “chat room” to express your opinion about the U.S. 

war on terrorism, the events related to September 11, Osama bin Laden, al 

Qaeda, or any other related issue? 

 Yes ____ No ____ 

 If yes, please describe. 

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99. How often do you think about the victims of the September 11th terrorist 

attacks or the families who lost members in these attacks? 

 Often _____ Sometimes _____ Rarely _____ Never _____ 

100. Have you watched or listened to any documentaries, television specials, or 

interviews, or other programs concerning the family members, friends, or 

co-workers of the victims of the September 11th hijackings? 

 Yes ____ No ____ 

 If yes, please describe. 

101. Have you watched or listened to any documentaries, television specials, or 

interviews, or any other program concerning the people who assisted in rescue efforts or aided victims in New York, Northern Virginia, and Pennsylvania? 

 Yes ____ No ____ 

 If yes, please describe. 

Contact, Knowledge, and Experience with Terrorism (Other than 

September 11, 2001) 

102. Have you seen any movies or read any books depicting or describing U.S. 

military efforts to combat terrorism? 

 Yes ____ No ____ 

 If yes, please describe. 

103. Have you read any books on Osama bin Laden, the al Qaeda network, terrorism, Afghanistan, Islam, fundamentalism, the Israeli–Arab conflict or 

other related topics? 

 Yes ____ No ____ 

 If yes, please describe. 

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104. How closely did you follow the media coverage of the events involving the 

bombing of U.S. embassies in Kenya and Tanzania, including the trial in 

New York? 

_____ Very closely 

_____ Somewhat closely 

_____ Not too closely 

_____ Not at all 

105. How closely did you follow the media coverage of the 1993 bombing of the 

World Trade Center Towers? 

_____ Very closely 

_____ Somewhat closely 

_____ Not too closely 

_____ Not at all 

106. How closely did you follow the media coverage of the Khobar Towers (Marine barracks) bombing in Saudi Arabia? 

_____ Very closely 

_____ Somewhat closely 

_____ Not too closely 

_____ Not at all 

107. How closely did you follow the media coverage of the attack on the U.S.S. 

Cole in Yemen? 

_____ Very closely 

_____ Somewhat closely 

_____ Not too closely 

_____ Not at all 

108. How closely did you follow the media coverage of Richard Reid, the man 

convicted of trying to light a shoe bomb on American Airlines Flight 63 

from Paris to the U.S. on December 22, 2001? 

_____ Very closely 

_____ Somewhat closely 

_____ Not too closely 

_____ Not at all 

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109. How closely did you follow the media coverage of the case of John Walker 

Lindh, the so-called “American Taliban”? 

_____ Very closely 

_____ Somewhat closely 

_____ Not too closely 

_____ Not at all 

110. Do you know anyone, including any attorney, investigator, witness, juror, 

law enforcement official, or court employee, associated with the trial of 

John Walker Lindh, the Virginia paintball case, Dr. Ali Al-Timimi, or 

Ahmed Abu Ali? 

 Yes ____ No ____ 

 If yes, please describe. 

111. Do you have strong feelings about the government’s efforts to fight terrorism? 

 Yes ____ No ____ 

 If yes, please explain. 

112. How closely have you followed media accounts that U.S. personnel have 

subjected members of al Qaeda to coercive interrogation techniques to obtain information as part of the war on terror? 

_____ Very closely 

_____ Somewhat closely 

_____ Not too closely 

_____ Not at all 

 Describe your understanding of those allegations. 

113. Do you believe that it is acceptable for U.S. personnel to use coercive interrogation techniques to obtain information from detainees as part of the war 

on terror? 

 Yes ____ No ____ 

 Please explain. 

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114. Do you believe that coercive interrogation techniques are more likely than 

non-coercive techniques to produce truthful answers during an interrogation? 

 Yes ____ No ____ No opinion ____ 

Knowledge About this Case 

115. Do you know, or have you had any contact whatsoever with, the defendant, 

Mr. Moussaoui? 

 Yes ____ No ____ 

 If yes, please explain. 

116. How much have you heard about this case? 

 A lot about the case 

 Some 

 Very little about the case 

 Nothing at all 

117. Have you ever visited this Court’s Website concerning this case? 

 Yes ____ No ____ 

 If yes, approximately how many times? __________ 

 Briefly describe what material you reviewed. 

118. How closely have you followed the news about this case? 

 Very closely 

 Somewhat closely 

 Not very closely 

 Not at all 

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119. (a) Please indicate from what source or sources you heard about the case. 

(Check as many as apply.) 

___ Television 

___ Newspapers 

___ Radio 

___ Internet 

___ Personal knowledge of accused, or his family, friends, or 

acquaintances 

___ Personal conversations with others in the community 

___ Overheard others discussing case 

___ Other sources of information. List. _________________________ 

 (b) Please describe as completely as possible what you have heard about 

this case. _________________________________________________ 

 _________________________________________________________ 

 _________________________________________________________ 

 _________________________________________________________ 

 _________________________________________________________ 

 _________________________________________________________ 

 _________________________________________________________ 

120. Have you read or heard about any specific statements attributed to the defendant, Zacarias Moussaoui? 

 Yes ____ No ____ Unsure ____ 

 Please describe. 

121. Have you heard any statements by any U.S. government officials concerning 

Mr. Moussaoui or his alleged involvement in the September 11 plot? 

 Yes ____ No ____ Unsure ____ 

 Please describe. 

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122. Have you read or heard any news articles or reports concerning Mr. Moussaoui’s psychological condition, mental state, or the presence or absence of 

any mental illness? 

 Yes ____ No ____ Unsure ____ 

 Please describe. 

123. Based on what you have read, heard, or seen in the media, please tell us 

what feelings or opinions you have formed about this case or about the defendant, Zacarias Moussaoui, or about what the appropriate outcome of the 

case should be, or the appropriate sentence. __________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

124. Based on this opinion, would it make it difficult for you to sit as a fair and 

impartial juror in this type of case? ________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

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Juror No. __________ 

34 

125. To the best of your knowledge, have you or any of your family members or 

close personal friends ever met or spoken with, observed, or had any personal knowledge of any of the nineteen men publicly identified as the September 11th hijackers? (Check all that may apply.) 

_____ Mohammed Atta 

_____ Abdul Aziz Alomari 

_____ Waleed M. al-Shehri 

_____ Waleed al-Shehri 

_____ Satam al-Suqami 

_____ Marwan al-Shehhi 

_____ Fayez Ahmed, a.k.a. “Banihammad Fayez” 

_____ Ahmed al-Ghamdi 

_____ Hamza al-Ghamdi 

_____ Mohald al-Shehri 

_____ Khalid al-Midhar 

_____ Nawaf al-Hamzi 

_____ Hani Hanjour 

_____ Salem al-Hamzi 

_____ Majed Moqed 

_____ Saeed al-Ghamdi 

_____ Ahmed al-Nami 

_____ Ahmed al-Haznawi 

_____ Ziad Jarrah 

 Please explain. 

126. Does the fact that this case involves a crime of massive violence cause you 

to question whether you can sit as a fair and impartial juror? 

 Yes ____ No ____ 

 If yes, please explain. 

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

 Yes ____ No ____ Not sure ____ 

 Please explain. 

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Juror No. __________ 

35 

128. Do you have any stake or personal or moral investment in the outcome of 

this case? 

 Yes ____ No ____ Not sure ____ 

 Please explain. 

Consideration of the Death Penalty 

129. At the present time, do you support or oppose the use of the death penalty? 

 Yes ____ No ____ Neither support nor oppose the death penalty ____ 

130. What are the reasons that you feel the way you do about the death penalty? 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

131. How strongly do you hold your present opinion concerning the death penalty? 

 Very strongly ____ Moderately ____ Not strongly at all ____ 

132. Has your opinion about the death penalty changed over time? 

 Yes ____ No ____ 

 If yes, in what way has your opinion changed? 

133. Do you or a family member belong to any group or organization that takes a 

position (by lobbying or otherwise) for or against the death penalty? 

 Yes ____ No ____ 

 If yes, describe the group or organization. 

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36 

134. Have you read any books or articles or seen any television shows or movies 

about the death penalty? 

 Yes ____ No ____ 

 If yes, which ones? 

135. Do you think the death penalty in the United States is used too often, about 

right, or too seldom? 

 Too often ____ About right ____ Too seldom ____ 

 Please explain. 

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Juror No. __________ 

37 

136. How important would each of the following factors be to you in making a 

decision between the death penalty and life in prison without the possibility 

of release? (Check one answer for each factor.) 

Not At 

All 

Important 

A Little 

Important 

Somewhat 

Important 

Very 

Important 

(a) A defendant 

given life without 

the possibility of 

release will 

remain in prison 

for the rest of his 

or her life. 

1 2 3 4 

(b) Someone who 

kills another 

always is a 

danger to others 

even if in prison. 

1 2 3 4 

(c) Even someone 

who kills can 

change for the 

better. 

1 2 3 4 

(d) When you take a 

life through 

intentional 

murder, you 

forfeit your life. 

1 2 3 4 

(e) Acts of terrorism 

that kill civilians 

deserve the 

ultimate 

punishment. 

1 2 3 4 

(f) Fundamental 

Islamic beliefs 

held by a 

defendant. 

1 2 3 4 

(g) Membership in 

al-Qaeda. 1 2 3 4 

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United States v. Moussaoui: Jury Questionnaire 

Juror No. __________ 

38 

Not At 

All 

Important 

A Little 

Important 

Somewhat 

Important 

Very 

Important 

(h) It is wrong to take 

a life even as 

punishment. 

1 2 3 4 

(i) The costs of 

keeping someone 

in prison. 

1 2 3 4 

(j) A defendant’s 

specific role in 

the offense. 

1 2 3 4 

137. In your opinion, is the death penalty in our society (check all that apply) 

_____ Useful? 

_____ Necessary? 

_____ Counterproductive? 

_____ Inhumane? 

_____ A deterrent? 

_____ Subject to error? 

_____ Morally justified? 

_____ Fair retribution? 

_____ Other? Please describe. ____________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

138. Why do you hold these feelings? __________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

 _____________________________________________________________ 

139. Do you believe in the concept of “an eye for an eye” and “a life for a life” 

with respect to the death penalty as punishment for intentional murder? 

 Yes ____ No ____ 

 Please explain. 

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Juror No. __________ 

39 

140. Do you believe that a sentence of life imprisonment without the possibility 

of release could ever be a severe enough sentence for someone convicted of 

conspiracy to commit acts of terrorism, conspiracy to commit air piracy, 

conspiracy to murder U.S. citizens, or conspiracy to use weapons of mass 

destruction, resulting in the deaths of thousands of people, as in the September 11th attacks on the United States? 

 Yes ____ No ____ Unsure ____ 

 Please explain your answer. 

141. In what way, if any, has your opinion about the death penalty changed as a 

result of the events related to September 11th and the war on terrorism? 

 More support for it ___ No change either way ___ More opposed to it ___ 

142. Would you be more likely to vote for the death penalty as punishment for 

the intentional, premeditated murder of a U.S. citizen through acts of terrorism than you would in other cases of intentional, premeditated murder? 

 Yes ____ No ____ Unsure ____ 

143. Based on what you have read or heard about this case, have you reached the 

conclusion that the death penalty would be the only appropriate sentence? 

 Yes ____ No ____ Not sure ____ 

 Please explain. 

Trial Procedures 

144. Since the Court has determined that your names and addresses will be kept 

confidential, will the fact that your name and address will not be revealed in 

any way affect your ability to be a fair and impartial juror to all the parties 

to this case? 

 Yes ____ No ____ Not sure ____ 

 Please explain. 

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Juror No. __________ 

40 

145. If you are selected to serve as a juror on this case, would you be concerned 

about reactions to the verdict by 

(a) Friends? Yes No 

(b) Relatives? Yes No 

(c) Co-workers? Yes No 

(d) Neighbors? Yes No 

(e) Members of your church, synagogue, mosque, 

or other house of worship? Yes No 

(f) The media? Yes No 

(g) People in this community? Yes No 

(h) Family and friends of victims? Yes No 

(i) Family and friends of the defendant? Yes No 

(j) People elsewhere in the U.S.? Yes No 

(k) People internationally? Yes No 

 If yes, what kind of concern or concerns do you have? Please explain. 

146. Is there any matter not covered by this questionnaire that you think the 

Court or the attorneys might want to know about you when considering you 

as a juror in this case? 

 Yes ____ No ____ Not sure ____ 

 Please explain. 

147. Are you a smoker? 

 Yes ____ No ____ 

 If yes, do you need to smoke more often than every two hours? Please explain. 

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Juror No. __________ 

41 

148. Do you know of any reason whatsoever why you cannot sit as a juror in this 

case and decide it fairly and impartially according to the law? 

 Yes ____ No ____ Not sure ____ 

 Please explain. 

149. If, during the course of jury deliberations, a fellow juror should suggest that 

you disregard the law or the evidence, and decide the case on other grounds, 

would you, as a juror, be able to reject the suggestion and abide by your oath 

to this Court to decide the case solely on the evidence and law as the Court 

has instructed you to do, without regard to sympathy, bias, or prejudice? 

 Yes ____ No ____ Not sure ____ 

 Please explain. 

150. Do you have any medical condition that would make it difficult for you to 

serve as a juror? 

 Yes ____ No ____ 

 If yes, please explain. 

 

151. Are you currently taking any prescription medication which may prevent 

you from giving your full attention to the matters in court during a trial? 

 Yes ____ No ____ 

 If yes, please explain. 

 

152. What is the condition of your hearing? 

 No problems at all 

 Have difficulty hearing 

 Have problems, but they are corrected with a hearing aid 

 If you have problems, please explain. 

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Juror No. __________ 

42 

153. What is the condition of your eyesight? 

 No problems at all 

 Have difficulty seeing 

 Have problems, but they are corrected by glasses or contact lenses 

 If you have problems, please explain. 

154. Do you have any specific problems concentrating or dealing with stress or 

pressure? 

 Yes ____ No ____ 

 If yes, please explain. 

 

155. Do you have any personal, professional, or financial obligations that would 

prevent you from giving your full attention or prevent you from being 

present in court for the duration of the trial? 

 Yes ____ No ____ 

 If yes, please explain. 

 

156. Do you know or recognize the judge in this case or any of the court personnel, attorneys, or potential witnesses? (See the attached list for the names 

of potential witnesses and other persons associated with this trial.) 

 Yes ____ No ____ 

 If yes, please give details. 

 

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

about this case? 

 Yes ____ No ____ Not sure ____ 

 Please explain. 

232 232
United States v. Moussaoui: Jury Questionnaire 

Juror No. __________ 

43 

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

in this questionnaire that creates a question in your mind as to whether you 

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

 Yes ____ No ____ Not sure ____ 

 Please explain. 

159. Is there anything else that you think the Court should know that might 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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United States v. Moussaoui: Jury Questionnaire 

Juror No. __________ 

44 

EXPLANATION SHEET 

234 234
United States v. Moussaoui: Jury Questionnaire 

Juror No. __________ 

45 

EXPLANATION SHEET (CONTINUED) 

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United States v. Moussaoui: Jury Questionnaire 

Juror No. __________ 

46 

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 February, 

2006. 

 ___________________________________ 

 Signature 

236 236
1 

United States v. Abu Ali: 

Preliminary Venire Instructions 

Hon. Gerald Bruce Lee 

Eastern District of Virginia 

October 25, 2005 

The following text was prepared by the Eastern District of Virginia’s United 

States District Judge Gerald Bruce Lee to address prospective jurors selected for 

the prosecution of a suspected terrorist in United States v. Abu Ali, No. 1:05-cr53 (E.D. Va. Feb. 3, 2005). 

Preview of Trial 

Good morning ladies and gentlemen. My name is Gerald Bruce Lee, and I am the 

judge who will preside over the trial of the case. 

The case we have for trial today is a criminal case entitled United States v. 

Mr. Ahmed Omar Abu Ali. Mr. Abu Ali is presumed to be innocent, and the purpose of this trial by jury is to determine if the Government can prove that the Defendant is guilty by proof beyond a reasonable doubt. Mr. Abu Ali has entered a 

plea of not guilty as to each of the charges. 

You are here today to be involved in the selection of a jury to hear the case. I 

will be discussing the charges in more detail in a moment. 

I want to first get started by stating what should be obvious but is, many 

times, misunderstood by many of us. The right to trial by jury is a fundamental 

right that each of us enjoys under the Constitution. We can only afford the essence of this right to those brought before our courts if all our citizens serve, no 

matter your station in life, your age, your education, or your background. In a 

very real sense, then, your presence today and your participation in this jury selection process are a part of a long-honored tradition involving hundreds of thousands of Americans over the years. 

We lawyers and judges, who have made our careers and crafted our livelihoods in these courtrooms, have long since come to realize that our courts can only work and deliver equal justice to all as long as we have fair trials by jury. We 

recognize that along with the benefits of United States citizenship and liberty 

come duties and responsibilities. I say this at the outset because we want you to 

know that we understand that jury selection always comes at an inconvenient 

time; there is never a convenient time for jury duty. There is never a convenient 

time to go to the hospital emergency room or to undergo emergency surgery. 

There is never a convenient time to go to court. This case will certainly be no 

different. 

This case in all likelihood will last for about three weeks, which amounts to 

twelve trial days, four days a week, Monday through Thursday. I anticipate this 

trial will begin for you on October 27, 2005, and continue until November 16 or 

later. We estimate the trial will require about three weeks in court, Monday 

through Thursday. So, to be clear, we anticipate bringing in the jury for jury selection procedures starting Tuesday, October 25, and we anticipate starting the 

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United States v. Abu Ali: Preliminary Venire Instructions 

2 

trial on approximately Monday, October 31, 2005, and we expect it to continue 

until November 17, 2005. We will be in court four days per week, Monday 

through Thursday, from 10:00 a.m. until 5:00 p.m., with an hour for lunch from 

1:00 to 2:00 p.m. 

I feel obliged to tell you that this will be a somewhat lengthy case for this 

court. Even if you were previously told that your term of jury duty is two weeks, 

if you are selected for the honor of serving on this jury, then you will have to stay 

with the case until it is completed, which will last much more than two weeks. I 

certainly will do my best to see that the case moves efficiently. These lawyers 

have never presented this case to a jury. The lawyers have been working on the 

case steadily for many months, so both sides are fully prepared to present the 

case to you without needless delay. 

With the exception of service in the armed forces and voting, there is no other duty of citizenship more important than jury service. The right to trial by jury 

is why we need you and insist on your involvement. 

Let me now introduce the parties in this case United States v. Mr. Ahmed 

Omar Abu Ali. Please pay attention to the appearance of each individual introduced, because later you will be asked if you know or are acquainted with any of 

these individuals. I’ll ask the parties to face you as they introduce themselves. As 

they introduce themselves, ask yourself if you are personally familiar with any of 

the lawyers or parties introduced in court. 

[Introduction of parties—by counsel.] 

Summary of Charges Against the Defendant 

Let me summarize the charges in this case. I do so only so that you can understand what this case is about. The charges are not evidence of guilt or anything 

else. Any evidence regarding these charges will come before you only when we 

begin the actual trial. I emphasize that what I am going to summarize now are 

just the charges, and these charges are not evidence. 

Go Through the Indictment Count by Count 

1. Count One charges the Defendant with conspiracy to provide material 

support and resources to a designated foreign terrorist organization (al-Qaeda). 

The indictment alleges that al-Qaeda is a worldwide terrorist organization dedicated to opposing non-Islamic governments, particularly the United States, with 

force and violence. Al-Qaeda was formed by Osama bin Laden and other individuals. 

The allegations in this case are that President William Clinton, in January 

1995 and 1998, issued an Executive Order 12947. As a result of finding that a 

variety of acts of violence by al-Qaeda constituted a threat to national security 

and foreign policy, the executive order prohibits any United States person from 

making or receiving any contribution of funds, goods, or services to or for the 

benefit of such persons. 

Additionally, President George W. Bush issued an executive order on September 23, 2001, that found that grave acts of terrorism and threats of terrorism 

were a threat to national security. President Bush’s Executive order 13224 prohi238 238
United States v. Abu Ali: Preliminary Venire Instructions 

3 

bited any future transaction or dealing by United States persons from making or 

receiving any contribution of funds, goods, or services to or for the benefit of 

persons in the al-Qaeda Islamic Army. 

On May 12, 2003, terrorist attacks were carried out against residential compounds in Riyadh, Saudi Arabia, resulting in the deaths of approximately 34 individuals including 9 Americans. 

Saudi Arabia officials sought out and arrested several individuals who belonged to clandestine terrorist cells in Saudi Arabia. Saudi officials were investigating the Riyadh bombings and terrorism in general at the time. 

During the questioning of one alleged terrorist cell member, the Saudi Arabian government informed the United States that the Defendant Mr. Abu Ali was 

allegedly identified as a terrorist cell member. Let me quickly say that there are 

no allegations in this indictment that Mr. Abu Ali was involved in the May 12, 

2003, Saudi Arabia bombings. Mr. Abu Ali is not charged with being involved in 

that incident, and Mr. Abu Ali is not on trial for that incident. 

The allegations are that the Defendant Mr. Abu Ali, while a student in a university in Saudi Arabia, came into contact with and agreed to join a conspiracy 

with other individual co-conspirators to plan and carry out certain terrorist acts. 

A conspiracy is an agreement between an individual and others to agree to commit a crime or what may be called a partnership in crime with others. The charges 

allege that Mr. Abu Ali joined a conspiracy to carry out several acts including: 

a. Allegations that the Defendant would become a planner of certain terrorist operations. 

b. Allegations that the Defendant discussed making plans with other coconspirators to plan an assassination of the President of the United 

States. 

c. Allegations that the Defendant decided to go to Afghanistan to join in a 

fight against United States military personnel in September 2002 and on 

June 9, 2003. 

d. Defendant allegedly offered himself to al-Qaeda as a person committed 

to furthering the objectives of the organization. 

e. Allegations that the Defendant accepted funds from co-conspirators in alQaeda to purchase a laptop computer, a cell phone, and books. 

f. Allegations that the Defendant did purchase these items. 

g. Allegations that the Defendant discussed with co-conspirators that he 

would help set up an al-Qaeda cell in the United States and carry out a 

terrorist operation here. 

This is just a brief summary of some of the allegations set forth in the charges. 

2. Count Two charges the Defendant with providing material support and 

resources to a designated foreign terrorist organization—al-Qaeda—between 

September 2002 and June 9, 2003. 

3. Count Three charges the Defendant with conspiracy to provide material 

support to terrorists. The allegations are that the Defendant entered into a conspiracy to provide material support and resources to al-Qaeda knowing and intending to prepare for and carry out the assassination of the President of the United States. 

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United States v. Abu Ali: Preliminary Venire Instructions 

4 

4. Count Four charges the Defendant with providing material support and 

resources to terrorists. The allegations are that the Defendant provided material 

support and resources to al-Qaeda knowing and intending that the resources or 

material support was to prepare for and carry out the assassination of the President of the United States. 

5. Count Five charges the Defendant with contribution of services to alQaeda. The allegations are that the Defendant made a contribution of services to 

and for the benefit of al-Qaeda, a specially designated terrorist organization under a regulation and in violation of a regulation and executive order signed by the 

President of the United States declaring al-Qaeda a terrorist organization. 

6. Count Six charges the Defendant with receipt of funds and services from 

al-Qaeda between September 2002 and June 9, 2003. 

7. Count Seven charges the Defendant with conspiracy to assassinate the 

President of the United States. 

8. Count Eight charges the Defendant with conspiracy to commit aircraft piracy. 

9. Count Nine charges the Defendant with conspiracy to destroy aircraft. 

Proof Beyond a Reasonable Doubt 

The foregoing are the charges against Mr. Abu Ali, and it is up to the Government to present evidence under oath before the jury and to prove the Defendant’s 

guilt, if it can, by proof beyond a reasonable doubt. Mr. Abu Ali has pleaded not 

guilty to each of these charges. In every criminal case brought in this country, it 

is the Government—the prosecution—that has the burden of proving by proof 

beyond a reasonable doubt a defendant’s guilt with respect to any charge 

brought. As I told you earlier, the Defendant is presumed to be innocent of the 

charges. Mr. Abu Ali is not required to prove that he is innocent or not guilty. 

Under our American criminal justice system, Mr. Abu Ali is not required to testify; he is not required to offer any evidence or to even to have his lawyers question the Government’s witnesses, because the burden of proof of every element 

of the charges is upon the Government. The fact that Mr. Abu Ali has been 

charged does not mean that he is guilty. Indeed, the purpose of this trial is to see 

if the Government can produce evidence that convinces you of his guilt beyond a 

reasonable doubt. Bear in mind that you have not seen one witness testify, and 

we do not know what the evidence will be. 

Juror Questionnaire 

Obviously, what I have just said is only an overview of the possible course of this 

trial and a shorthand summary of the law. I am giving you this information because shortly I will hand out a jury questionnaire for you to complete. I went over 

all of this because I need you to think about it in order to prepare to answer the 

jury questionnaire and to answer my questions when you return to court later for 

individual questioning. 

Now, in a few minutes I am going to ask the assembled jury panel to complete a confidential jury questionnaire. The jury questionnaire is to be completed 

240 240
United States v. Abu Ali: Preliminary Venire Instructions 

5 

in full, under oath, and to the best of your ability. The jury questionnaire will only be available for jury selection by the lawyers and the judge. The jury questionnaire will not be available to any media because I am placing the answers under 

seal to protect your privacy. If you have any questions about the jury questionnaire, please write them down and provide them to the Court Clerk, Ms. Solomon. Ms. Solomon will answer any questions she can about how to complete the 

jury questionnaire and if you believe that only the judge can answer your questions, then I will answer your questions here in court. If at any time you believe 

that your question or the answer to it may contain personal information that you 

would prefer not to have to respond to in the presence of your fellow jurors, 

please let me know that and we can take up your questions outside the hearing of 

your fellow jurors. 

Hardship Questions, Excuse 

The Juror Questionnaire asks for information about juror schedule conflicts or 

hardship or medical problems. Please write down any information you want me 

to know on the explanation sheet. Understand, as I said at the outset, that the 

court is not going to excuse many jurors because of job conflicts, children in 

school, or just because you are busy. Only really compelling reasons will require 

me to excuse you from this case. I will read all the questionnaires requesting an 

excuse and you will be informed of my answer. After you complete the questionnaire you will be told when to call the jury phone number on , 2005, 

after 5:00 p.m. to learn when you have to come back to court for individual questioning. On your designated day, you will either be asked to come in to Court at 

10:00 a.m. or 2:00 p.m. When you return to Court, I will speak to each of you 

individually and ask you a few additional questions. Let me note three additional 

comments. 

First, I want to emphasize that if you are selected for this jury your only duty 

will be to decide whether the Government has established the Defendant’s guilt 

by proof beyond a reasonable doubt. If, after hearing all the evidence in trial, the 

jury is of the unanimous opinion that the Government has not shown the Defendant to be guilty, then the law requires you to return a verdict of not guilty and 

the charges will be dismissed. 

On the other hand, if after hearing all the evidence in trial, the jury is of the 

unanimous opinion that the Government has shown the Defendant to be guilty, 

then the law requires you to return a verdict of guilty. You are not to concern 

yourself with punishment, because under the law, the judge will apply the United 

States Sentencing Guidelines, consider information not presented to you about 

the Defendant’s background, and the judge will then impose a sentence according 

to law. The jury must not consider possible punishment in any way in this trial. 

Second, please remember to call the jury phone number and remember to 

come back to court when you are supposed to return. You would be shocked to 

see the number of people we have to bring to court with the marshals who walk 

in here and say “I forgot.” Nothing is more embarrassing than to come to federal 

court and to tell a judge in a crowded courtroom “I forgot.” I promise you that if 

you forget and fail to report back to court when you are supposed to, I will send 

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United States v. Abu Ali: Preliminary Venire Instructions 

6 

the United States Marshal to your home or office to require you to come back to 

court. Our marshal’s service is busy with other cases that I am sure you are aware 

of, so please do not make me have to send them out for a juror who “forgot.” 

Place a string around your finger, write yourself a note, but do not forget to return to court. Your return-to-court date is as important as showing up at the hospital for a heart transplant operation. This jury duty is serious business and we 

need your undivided attention. Let nothing get in the way of returning to court 

for your appointment when you are directed to return. 

Understand that when you return to court this process will take some time so 

bring something to read while you wait and please be patient with us as we go 

about this process. There is no easy way to conduct jury selection and we are 

going to try our best not to unnecessarily waste your time. 

Third and finally, I recognize that jury duty is an imposition and a responsibility of citizenship. Next to the right to vote, jury duty is when you give back to 

your country in a way that affects human lives. If you have never served on a 

jury before, I assure you there is no experience comparable to it. There is no experience similar to acting as a judge of the facts in a criminal case as a juror. 

There is no experience you will have that will bring you closer to the ideals of 

our great nation than jury duty. Jury duty is not the draft and no one is asking you 

to take up with the military here. 

Today is not a time to tell the judge I am too busy to serve. Today is not a 

day to tell the nation, I do not have time to serve on a jury. 

What I mean is that what we are talking about here—jury duty—is just that: 

a duty of citizenship and an honor. We recognize, of course, that jury duty rarely 

comes at a convenient time. There is always something—day-to-day living, important jobs or projects at work, a meeting, elderly relatives to care for, medical 

appointments, vacations, and other plans. Your employer may not deprive you of 

the right to serve on a jury, and if any of you has a problem with your employer 

allowing you to be off work for jury duty, you let me know and we can bring the 

employer to court and straighten that out for your employer. If you need a note 

saying you will be on jury duty, let us know and the clerk can prepare it for you. 

We understand that jury duty will be inconvenient for work and other things in 

life. 

Jury duty arrives when we would rather be doing something else, which is 

why I rarely allow excuses from jury duty. Each of us is busy, and if I excuse 

every juror who has something to do, then the courts will be left only with those 

who have nothing better to do or maybe just those who are idle. I suppose we 

could go to nursing homes or retirement communities and secure individuals who 

do not work, but that would not be fair. We want busy and engaged people like 

you who represent a broad cross-section of our community to serve as jurors. We 

think that juries that are inclusive of Americans of a variety of backgrounds, 

ages, gender, education, and cultures will make for sound judgments in the jury 

room. Indeed, the founders of this country thought that the right of a jury 

representing average people in the community was so important that they provided for it in the Constitution. 

242 242
United States v. Abu Ali: Preliminary Venire Instructions 

7 

The Media 

This case has received, and probably will continue to receive, some media attention, so I must instruct you—I am instructing you now—not to read, watch television, listen to radio, read any newspaper or magazine, and not to conduct any 

internet or google searches about this case or Mr. Abu Ali. If you see or hear anything related to this case, turn off the television or radio. You are instructed to 

refrain from media exposure and you are instructed not to conduct any research. I 

want the jury to receive information about this case here—in trial—from witnesses under oath, in the presence of the accused, the Government, and your fellow jurors. Please do not accept any statements in the media as evidence because 

they are not evidence. The media do not know what evidence will be presented 

here in court. Indeed, the thirty-second summaries in the media or stories of the 

most sensational aspects of a trial rarely capture what the twelve jurors who are 

seated in the courtroom for five to six hours a day observe. What is reported in 

the media are called “news stories” for a reason. They are not transcripts or recordings of what actually occurs in a trial. If you have seen or read reports, 

please just answer the questions in the questionnaire honestly. Media exposure 

alone will not get you out of jury duty. 

Final Instructions 

Please approach your preparation of the Juror Questionnaire not grudgingly or 

negatively. Consider it an honorable undertaking worthy of your time and interest. 

Remember: if you have questions about the instructions or a particular question, please feel free to ask the Courtroom Clerk, Ms. Jo Solomon. Please ask the 

court security officer for a piece of paper to write down your question before you 

approach the Courtroom Clerk. After you complete your questionnaire, turn it in 

to the clerk and get your report date phone call information. 

I will leave the courtroom now to allow you time to complete the questionnaire. If you need me to return to the bench to answer a question in open court, I 

am available to answer questions. On behalf of our court staff and these parties, 

let me thank you for your patience and cooperation. 

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1 

United States v. Abu Ali:

Jury Questionnaire

Hon. Gerald Bruce Lee

Eastern District of Virginia

October 25, 2005

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

United States District Judge Gerald Bruce Lee to facilitate jury selection in a 

prosecution for terrorism, United States v. Abu Ali, No. 1:05-cr-53 (E.D. Va. Feb. 

3, 2005).

Instructions for Jury Questionnaire

This questionnaire is designed to obtain information about your background as it 

relates to your possible service as a juror in this case. Its use may avoid the necessity of asking these questions of each prospective juror in open court, thereby 

substantially shortening the jury selection process. The purpose of these questions is to determine whether prospective jurors can impartially decide this case 

based upon the evidence presented at trial and the instructions on the law given 

by the presiding judge. The questions are not intended to unnecessarily inquire 

into personal matters. All information contained in this questionnaire will be kept 

confidential, under seal by the court, and will not be available to the public or 

media.

Respond to each question as fully and completely as possible. Your complete 

candor and honesty is necessary so that both the prosecution and the defense will 

have a meaningful opportunity to select an impartial jury. Your cooperation is of 

vital importance.

You are sworn to give true and complete answers, and those answers will be 

available only to the court and the parties in this case. This questionnaire belongs 

to the court, and all copies will be returned to the court once a juror is excused. 

You are instructed not to discuss this case or the questionnaire with anyone, including your family and fellow jurors.

If you require additional space for your responses or wish to make further 

comments regarding any of your answers, please use the Explanation Sheet located at the end of the questionnaire. Put the number of the question you are 

answering on the Explanation Sheet before you write your response or comment.

Please keep in mind that there are no right or wrong answers, only complete and incomplete answers. Complete answers are far more helpful than incomplete answers.

Unless the question states otherwise, the fact that a particular question is asked 

does not imply that the subject matter of the question is an issue in this case. As 

you read the questions, you are not to draw any inferences about the issues that 

must be decided in this case.

Please fill out the entire questionnaire. Do not leave any questions blank. If a 

question does not apply to you in any way, write N/A rather than leaving the 

question blank.

PLEASE PRINT LEGIBLY PLEASE USE ONLY DARK INK

THANK YOU FOR YOUR TIME AND ATTENTION

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 2 

Jury Questionnaire

United States v. Ahmed Omar Abu Ali, 05-cr-53

Background

1. Name: 2. Where do you currently reside? City: County: 3. How long have you lived at your current address? years months

4. Are you: Male Female 

5. How old are you? years

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. What is your current marital status? Married Single/Never Married Widowed Separated or Divorced 

For 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.

11. Are you, your spouse, or former spouse a naturalized U.S. citizen? Yes No 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 3 

12. Are you employed?

Yes No (a) If employed, what is your current occupation/job title? (b) How long have you held this job? years months

(c) Name of employer: (d) If retired, what was your occupation/job title? 

 Where did you work? (e) If between jobs, what was your last position?  Where did you work? (f) If you are a student, where do you attend school?  13. Do you have a second job? Yes No  

If yes, what do you do? 14. Check the highest level of education attained by you and your spouse: You Spouse 

Grade school or less _____ _____ Some high school _____ _____ High school graduate _____ _____ Technical/vocational/business school _____ _____ Some college _____ _____ College degree (indicate degree below) _____ _____ Some graduate education _____ _____ Graduate degree (indicate degree below) _____ _____ Your degrees held: 

 Your area(s) of study/major: 15. What is your current religious affiliation? If none, write none. 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 4 

16. Have you had any previous religious affiliations?

Yes No 

 If yes, please list your previous religious affiliations, in chronological order, 

with your most recent affiliation first. 

 17. A number of the audio- and videotaped conversations that you will hear during trial will be in Arabic. Written translations of the conversations will be 

given to the jury as the tapes are played. Do you have any physical disability 

that would make it difficult for you to listen to or see the tapes and translations? Yes No 

 If yes, please explain. 

18. Is there any reason that it would be hard for you to pay attention to a lengthy 

video- or audiotape? Yes No Nature of the Case

19. Under our United States Constitution, the defendant, Mr. Abu Ali, is presumed to be innocent, and he cannot be found guilty of any offense unless 

and until the government has proven each element of that offense beyond a 

reasonable doubt. Do you accept this principle and agree to apply it? Yes No 20. The defendant is not required to testify or to present his side of the story to 

the jury at all. Under our United States Constitution, the defendant has the 

absolute right to remain silent, and the jury may not consider the fact that the 

defendant chooses not to testify as any evidence against him. Do you understand that the defendant s silence may not be held against him, and that you 

may not consider it in your deliberations? Yes No Criminal Procedure

21. Do you believe that if the prosecution brings a person to trial, that person is 

probably guilty?

Yes No Unsure 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 5 

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

did not commit? 

Yes No Unsure 

23. A number of trial witnesses may be law enforcement officers. Do you feel 

that because of your attitudes about, or experiences with, law enforcement 

officers, the testimony of a law enforcement officer is entitled to greater, or 

less, weight than a regular citizen witness simply because of his or her status 

as a law enforcement officer? Yes No 24. At the conclusion of the case, it is the Courts task and duty to instruct you 

on the law and explain to you the elements of the crimes charged in the indictment. Do you have any 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 

 

If yes, please explain. 

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

defendant, Ahmed Omar Abu Ali, or to the government in this case? Yes No 

 

If yes, please explain. 

Knowledge of Arabic, Islam, and the Middle East

26. Do you speak, read, write, or understand the Arabic language or any dialect 

of Arabic? Yes No 

 

If yes, please indicate your proficiency by checking the appropriate box: Beginning Intermediate Conversational Fluent

Reading Writing Understanding Speaking 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 6 

27. Did you grow up in households where the Arabic language, or any of its dialects, was spoken? Yes No 28. Have you had any formal training in the Arabic language, the Urdu language, 

or any of their dialects? Yes No 

 If yes, please state where the training occurred, and for how long.  29. Do you read any Arabic language or Urdu language newspapers or publications? Yes No  If yes, please list the Arabic language or Urdu language newspapers or publications.  30. Do you watch any Arabic language television programs, including newscasts? Yes No  

If yes, please list the programs or newscasts. 

31. The defendant in this case is of Arab or Middle Eastern descent. Are you, 

your spouse, any member of your immediate family, or any of your close 

personal friends of Arab or Middle Eastern descent? Yes No 32. Were you, your spouse, any member of your immediate family, or any of 

your close personal friends born in the Middle East? Yes No 

 

If yes, where? 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 7 

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

your close personal friends lived, worked, or traveled (or is any of these currently living, working, or traveling) in any of the following countries: Afghanistan, Egypt, Iran, Jordan, Kuwait, Iraq, Israel, Lebanon, Libya, Palestine, 

Pakistan, Qatar, Saudi Arabia, Sudan, Syria, United Arab Emirates, or Yemen? Yes No 

 If yes, please explain. 

34. Do you, your spouse, any member of your immediate family, or any of your 

close personal friends have any business or property interests in any of the 

following countries: Afghanistan, Egypt, Iran, Jordan, Kuwait, Iraq, Israel, 

Lebanon, Libya, Palestine, Pakistan, Qatar, Saudi Arabia, Sudan, Syria, 

United Arab Emirates, or Yemen? Yes No 

 

If yes, please explain. 

35. Is there anything about a case where a defendant, or a witness, is Muslim 

(which means he or she practices the Islamic faith) that would make it difficult for you to serve as a fair and impartial juror? Yes No 

 

If yes, please explain. 

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

Muslim faith (Islam)? Yes No 

 

If yes, please describe your relationship to that person and whether you have 

discussed that person s faith with him or her. 

 

37. Do you believe that Islam endorses violence? Yes No 38. Have you ever visited a mosque? Yes No 

 

If yes, what were the circumstances of the visit? 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 8 

39. Do you have any impressions of the Saudi Arabian criminal justice system? Yes No 

 If yes, please explain. 

40. Have you heard of the Saudi Mabahith? Yes No 41. Do you have an opinion about Muslim charities? Yes No 

 If yes, please explain. 

42. Do you personally know anyone who is of Arab or Middle Eastern descent? Yes No 

 

If yes, please describe your relationship to that person and whether you have 

discussed that person s ethnic background with him or her. 

43. How knowledgeable are you about the history, traditions, and practices of the 

Muslim faith (Islam)? Very knowledgeable Somewhat knowledgeable Not too knowledgeable Not at all knowledgeable 

44. Do you have any feelings, positive or negative, about the Muslim faith (Islam)? Yes No 

 

If yes, please describe them. 

45. Is there anything about Islamic teachings or doctrine that is personally offensive to you? Yes No 

 

If yes, please explain. 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 9 

46. Have you, or anyone you know, ever worked in a civilian or non-military 

government capacity anywhere in the Middle East, including but not limited 

to Afghanistan, Egypt, Iran, Iraq, Israel, Jordan, Kuwait, Lebanon, Libya, Palestine, Pakistan, Qatar, Saudi Arabia, Sudan, Syria, United Arab Emirates, 

or Yemen? Yes No 

 If yes, who, when, where, and what type of work? Please do not list the employer. 

47. Do you know anyone who presently resides in the Middle East? Yes No 

 If yes, who and where? 

48. Do you work, or have you worked in the past, with people of Middle Eastern 

descent? Yes No 49. Do you socialize with people of Middle Eastern descent? Yes No Government or Military Affiliation

50. Have you, your spouse, or any member of your immediate family ever served 

in the armed forces? Yes No (a) If yes, please give the following: Branch and 

Highest 

Rank

Dates of 

Service

Type of 

Discharge

You Spouse Other Family 

Members 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 10

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

ever been involved in a court martial?

Yes No 

 If yes, please explain. 

(c) If you, your spouse, or any member of your immediate family has 

served in the military, were you, or they, ever in a combat situation?

Yes No 

 If yes, please state who, where, and when. 

51. Have you or any close family members or friends served in a combat or a 

military zone in Afghanistan, Iraq, or elsewhere in the Middle East? Yes No 

 

If yes, indicate who, when, and the circumstances under which they served. 

52. Have you, your spouse, any member of your immediate family, or any of 

your close personal friends been injured or killed while serving in a combat 

or a military zone in Afghanistan, Iraq, or elsewhere in the Middle East? Yes No (a) If yes, please explain. 

 

(b) Does the above experience affect your perception of Muslims? If so, 

please explain. 

 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 11

53. Have you, your spouse, any of your immediate family members, or any of 

your close personal friends been employed by, applied for employment with, 

or volunteered with any of the following organizations or agencies? (Check 

all that apply.) You Spouse

Friend/ 

Family 

Member

Any law enforcement agency (such as 

a police or sheriff s department; the 

Federal Bureau of Investigation (FBI); 

Drug Enforcement Agency (DEA); 

Bureau of Alcohol, Tobacco, and 

Firearms (ATF); U.S. Marshals 

Service; U.S. Park Police; U.S. Justice 

Department; a District, 

Commonwealth, or State s Attorney s 

Office; a probation or parole office; 

Bureau of Prisons; Department of 

Corrections; military police; or private 

security police) Any local, state, or national security or 

self-defense agency (including the 

Department of Homeland Security) Any military or civilian intelligence 

agency (including CIA, DIA, NSA) The office of any member of the U.S. 

Senate, any member of the U.S. House 

of Representatives, or any 

congressional committee or 

subcommittee The White House or Office of the 

President 

 

If yes, please explain. 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 12

Personal Experience 

54. Do you, your spouse, any member of your immediate family, or any of your 

close personal friends know anyone who was a victim or 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. 

55. Was anyone in your family, or any close friend, injured or killed in the attacks on the World Trade Center and the Pentagon, or on the flight that was 

downed in Pennsylvania, on September 11, 2001? Yes No 56. In light of the fact that the allegations in this case involve al-Qaeda, can you 

render an impartial verdict in this case? Yes No 57. In light of the fact that there are allegations in reference to Osama bin Laden, 

can you still render an impartial verdict in this case? Yes No 58. Have you, your spouse, any member of your immediate family, or any of 

your close personal friends ever been confined or detained involuntarily by a 

government or military authority (for example, in jail, in prison, or as a prisoner of war)? Yes No (a) If yes, please explain. 

 

(b) If yes, were you, your spouse, your immediate family member, or your 

close personal friend ever subjected to mistreatment while in confinement? Yes No 

If the answer to (b) is yes, please explain. 

 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 13

59. Do you, your spouse, any member of your immediate family, or any of your 

close friends know anyone who has been arrested, detained, or imprisoned in 

a foreign country? Yes No 

 If yes, please explain. 

60. Have you ever experienced discrimination against you on account of your 

religious beliefs? Yes No 

 If yes, please explain. 

Special Expertise

61. Do you or your spouse have any specialized education, training, work experience, or expertise in any of the following areas? (Check all that apply.) You Spouse 

(a) Criminal justice or law enforcement _____ _____ (b) Firearms or explosives _____ _____ (c) History, political science, or government _____ _____ (d) Middle East history or area studies _____ _____ (e) Journalism or media _____ _____ (f) Law or legal studies _____ _____ (g) Military history or military studies _____ _____ (h) Religion or philosophy _____ _____ (i) Foreign languages or linguistics _____ _____ (j) Computer science _____ _____ If yes to any of these, please list and describe the training, experience, or expertise. 

 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 14

62. Do you have regular access to the Internet? Yes Yes, but only at work No 

 If yes, or yes, but only at work, about how often do you access the Internet? Stay connected for extended periods throughout the day A few times a day Daily A few times a week A few times a month A few times a year

Exposure to Media Coverage of This and Other Cases

63. Ahmed Omar Abu Ali is a United States citizen and a resident of Northern 

Virginia. He has been a student at the Saudi Islamic Academy in Falls 

Church, Virginia, at the University of Maryland, and at the Islamic University in Medina, Saudi Arabia. In this case, the defendant is charged with conspiracy to provide material support and resources to foreign terrorist organizations, providing material support and resources to foreign terrorist organizations, contributing services to and receiving funds from al-Qaeda, conspiracy to assassinate the President of the United States, conspiracy to commit 

aircraft piracy, and conspiracy to destroy aircraft. This case has received 

some publicity. Have you seen, heard, or read anything about the defendant 

or this case? (This includes not only from the media e.g., newspaper, TV, 

radio, Internet, etc. but also anything you may have heard from friends, relatives, or co-workers.) Yes No (a) If yes, please explain what you have seen, heard, or read and from what 

source(s). 

 

(b) Is there anything you have seen, heard, or read about this case that would 

interfere with your ability to render a fair verdict based solely on the evidence presented in court?

Yes No If yes, please explain. 

 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 15

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

Ahmed Omar Abu Ali, in this case?

Yes, I have formed an opinion No, I have not formed an opinion 

65. Have you heard or read about any allegations made by the defendant, Ahmed 

Omar Abu Ali, that he was tortured while in custody in Saudi Arabia? Yes No (a) If yes, please describe what you have heard or read. 

 (b) If yes, would you be able to put aside what you have read and fairly consider the evidence presented at trial on this issue? Yes No 66. Have you read or heard any news coverage or received information from any 

other source regarding a criminal case in Northern Virginia referred to as either the Virginia Jihad case or the Virginia Paintball case? 

Yes No 

 

If yes, please describe what you have read or heard and from what source. 67. Do you know anyone who was a defendant, witness, lawyer, investigator, or 

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

Northern Virginia described as the Virginia Jihad case or the Virginia 

Paintball case? 

Yes No 

 

If yes, please explain. 

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

other source regarding a criminal prosecution in Northern Virginia of an individual named Ali al-Timimi? Yes No 

 

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

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 16

69. Do you know the defendant or anyone who was a witness, lawyer, investigator, or was otherwise involved or associated in any way with a criminal prosecution in Northern Virginia of an individual named Ali al-Timimi? Yes No 

 If yes, please explain. 

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

ensure that this case is decided solely on the evidence in the courtroom and is 

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

the Court will require that you avoid reading about the case in the newspapers and listening to any radio or television reports about the case. The Court 

also requires that you avoid discussing this case with friends and family during the course of the trial. You will also be prohibited from using 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 Policy Issues 

71. Do you have an opinion regarding the relationship between the governments 

of the United States and Saudi Arabia, particularly as it relates to combating 

terrorism? Yes No 

 

If yes, what is your opinion? 

72. Do you have an opinion regarding the human rights practices of the government of Saudi Arabia? Yes No 

 

If yes, what is your opinion? 

73. Do you believe that the United States Governments efforts to combat terrorism against the United States have unfairly targeted Arab Americans?

Yes No No opinion 

 

If yes, please explain. 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 17

74. Do you believe that using physical violence to get information is acceptable 

in cases involving national security? Yes No 75. Do you believe that torture can be both physical and mental? Yes No 76. Do you feel that physical violence is an effective means of procuring a confession? Yes No 77. Do you believe there is a law enforcement bias against people of Middle 

Eastern descent or people of the Islamic faith? Yes No 

 If yes, please explain. 

78. Are you, or have you ever been, a member of any human rights advocacy 

group? Yes No 

 

If yes, please explain and include the name of the group. 

 79. Do you, your spouse, any of your immediate family members, or any of your 

close personal friends belong to any organization that deals with, or attempts 

to influence, United States foreign policy in the Middle East? Yes No 

 

If yes, please indicate the person, name the organization, and describe the 

involvement. 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 18

Conflicts of Interest and Knowledge of Parties

80. The government is represented in this case by United States Attorney Paul J. 

McNulty, although the conduct of the case is the responsibility of a team of 

government attorneys. To your knowledge, do you, your spouse, any of your 

immediate family members, or any of your close personal friends know or 

have any connection with any of the following individuals, who are involved 

with prosecuting the case for the government? 

Paul J. McNulty, United States Attorney Yes No 

David H. Laufinan, Assistant United States Attorney Yes No 

Stephen M. Campbell, Assistant United States Attorney Yes No 

Robert A. Spencer, Assistant United States Attorney Yes No 

Jerry R. DeMaio, Trial Attorney, U.S. Department 

 of Justice Yes No 

Maria Tusk, Special Assistant United States Attorney Yes No 

Barry Cole, Special Agent, FBI Yes No 

(a) If yes, please explain. 

 

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

(This includes not only from 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(s). 

 81. Do you know anyone in the United States Attorney s office in Alexandria, 

VA, or elsewhere? Yes No 

 

If yes, please indicate who and explain the nature of your relationship. 

82. Do you, your spouse, any member of your immediate family, or any of your 

close personal friends know or have any connection with the defendant, 

Ahmed Omar Abu Ali, or any member of his family, including his father 

Omar Abu Ali, his mother Faten Abu Ali, or his siblings Tasneem, Amin, 

Maryam, or Mohammed Abu Ali? Yes No 

 

If yes, please explain. 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 19

83. Have you, your spouse, any of your immediate family members, or any of 

your close personal friends 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. 

84. The defendant, Ahmed Omar Abu Ali, is represented by several attorneys: 

Ashraf Nubani, whose office is in Annandale, Virginia; Khurrum Wahid, 

whose office is in Miami, Florida; Carmen Vizcaino, whose office is in Miami, Florida; and Nina Ginsberg, whose office is in Alexandria, Virginia.

(a) To your knowledge, do you, your spouse, any member of your immediate family, or any of your close personal friends know or have any 

connection with any of these lawyers, their offices, or their staffs?

Attorney Ashraf Nubani Yes No 

Attorney Khurrum Wahid Yes No 

Attorney Carmen Vizcaino Yes No 

Attorney Nina Ginsberg Yes No 

If you answered yes for any of these individuals, please describe the 

connection. 

 

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

(This includes not only from 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(s). 

 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 20

85. Do you, your spouse, any member of your immediate family, or any of your 

close personal friends have any connection with, or have you ever seen, 

heard, or read anything about any of the individuals listed below, who may 

be witnesses or who may be mentioned at trial? Mohammed Adra Dennis Hankins Christopher Odell Beth Babyak Willie T. Hulon Dan Olson Brian Balgaard Maria Jocys Glenn Posto Merry Brinkley Dr. Robert Katz Alison Rees Sara Chervenak Gordon Kromberg Leigh Rieder Barry Cole Luke Kuligoski Dr. Gregory Saathoff Patrick Cook David Laufman Kenneth Sackett Dina Corsi Sarah Web Linden Dr. Richard Schwartz Ed Cramer Viktoria Lopakiesicz Lee Shepps Tonya Creavalle Elias Machanaly Gilbert Sperling Alex Daghestani Christopher Mamula Monica Trachesel Patrick M. Gillen Michael Mason Charles Wilmore Charles Glatz Sylvia McCarthy John Wyman Sgt. Robert McCray-Brown Yes No 

 

If yes, please list the individual s name and explain the connection or what 

you have seen, read, or heard and from what source(s). 

86. Do you know any of the other prospective jurors called to serve in this case? Yes No 

 

If yes, please identify the prospective juror(s) and explain how you know 

them. 

87. The judge who will preside over this case is The Honorable Gerald Bruce 

Lee of the United States District Court for the Eastern District of Virginia. 

Do you, your spouse, any member of your immediate family, or any of your 

close personal friends know or have any connection with Judge Lee or any of 

his staff? Yes No 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 21

Experience with the Criminal Justice System

88. Have you, your spouse, any member of your immediate family, or any of 

your close personal friends ever been charged with a crime or been the subject of a criminal investigation? Yes No 

 If yes, please explain. 

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

proceeding? Yes No 

 If yes, please explain. 

90. Have you ever been questioned in any matter by a local, state, or federal law 

enforcement agency, including any police or sheriffs office, the Federal Bureau of Investigation (FBI), the Drug Enforcement Administration (DEA), 

the Bureau of Alcohol, Tobacco, and Firearms (ATF), the Department of Justice, the Department of Homeland Security, the Internal Revenue Service 

(IRS), or the Bureau of Immigration and Customs Enforcement (ICE), formerly known as the Immigration and Naturalization Service (INS)? Yes No 

 

If yes, please explain. 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 22

91. Have you ever:

(a) Served as a juror in a crinunal case? Yes No 

 (b) Served on a grand jury? Yes No 

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

(d) Served as foreperson on a jury? Yes No 

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

was unable to reach a verdict? Yes No 

 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) whether you served as foreperson; (5) what the 

general nature of the case was (for example, robbery, murder, contract, negligence, medical malpractice, etc.); (6) whether or not a verdict was reached; 

and (7) if there was a verdict, what the verdict was.

Year

State or

Federal

Jury?

Grand

Jury or

Trial

Jury?

Were You 

the

Foreperson?

(Yes/No) 

Nature of 

Case

Was There

a Verdict?

(Yes/No) 

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. 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 23

92. 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, 

agents, or employees of the United States? Yes No 

 If yes, please explain. 

93. There may be evidence introduced in this case about the activities of American and foreign intelligence services. Do you have any strong feelings about 

American intelligence services or foreign intelligence services? Yes No 

 If yes, please explain. 

94. There may be testimony in this case by officers of the Saudi Arabian domestic security service, known as the Mabahith. Would you have any difficulty 

giving fair consideration to their testimony? Yes No 

 

If yes, please explain. 

95. There may be evidence introduced in this case consisting of reports by the 

U.S. State Department about the human rights practices of the government of 

Saudi Arabia. Are you familiar with these reports? Yes No (a) If yes, please explain. 

 

(b) If yes, do you have an opinion about the truth or accuracy of these reports? Yes, I have an opinion No, I do not have an opinion 

The trial will start on or about October 27, 2005, and will last approximately 

three (3) weeks. Most weeks, the jury will sit four days per week, from approximately 10:00 a.m. to 5:00 p.m. We will not sit on Fridays. 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 United States 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 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 24

service will not be enough to excuse you from service. You must show that service as a juror in this case would cause an unacceptable personal hardship. 

96. Would you have a serious hardship if chosen for this case? Yes No 

 If yes, please explain. 

97. Do you have any problem with your hearing or vision, or do you have any 

other medical condition that would interfere with your service as a juror? Yes No 

 If yes, please explain the condition, and how it would interfere. 

98. Are you taking any medication that may interfere in any way with your ability to concentrate or to serve as a juror? Yes No 

 

If yes, please explain how the medication would interfere. 

 99. 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 affect your jury service in this case, or that 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. 

100. Is there anything you would prefer to discuss privately with the judge? Yes No 

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 25

AFFIRMATION

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 October, 

2005. _________________________________ Signature 

268 268
United States v. Abu Ali: Jury Questionnaire Juror No. __________ 26

EXPLANATION SHEET

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United States v. Abu Ali: Jury Questionnaire Juror No. __________ 27

EXPLANATION SHEET (CONTINUED)

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270 270
 

1 

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 

271
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 2 

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: 

272 272
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 3 

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 

273
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 4 

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? 

274 274
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 5 

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. 

275
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 6 

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. 

276 276
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 7 

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? 

277
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 8 

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? 

 

278 278
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 9 

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. 

279
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 10

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. 

280 280
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 11

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. 

281
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 12

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 

282 282
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 13

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 victims 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. 

283
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 14

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. 

284 284
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 15

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. 

285
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 16

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. 

286 286
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 17

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

287
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 18

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? 

288 288
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 19

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 

289
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 20

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.

290 290
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 21

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. 

291
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 22

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 

292 292
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 23

EXPLANATION SHEET

QUESTION NUMBER EXPLANATION 

 

293
United States v. Al-Timimi: Jury Questionnaire Juror No. __________ 24

EXPLANATION SHEET (CONTINUED)

QUESTION NUMBER EXPLANATION 

 

294 294
1 

United States v. Koubriti:

Preliminary Voir Dire

Hon. Gerald E. Rosen

Eastern District of Michigan

March 18, 2003

The following text was prepared by U.S. District Judge Gerald E. Rosen of the 

Eastern District of Michigan to address 280 prospective jurors selected for a 

high-pro le prosecution of suspected terrorists in United States v. Koubriti, No.

2:01-cr-80778 (E.D. Mich. Sept. 27, 2001). Judge Rosen adapted these remarks 

from remarks prepared for another case by U.S. District Judge Michael Mukasey 

of the Southern District of New York, who retired in 2006.

Preliminary Voir Dire

Good morning, ladies and gentlemen. I’m Judge Gerald Rosen, and we’re here 

this morning to begin the process of picking a jury in a criminal case. Our purpose today and in the coming weeks is to pick a jury of citizens who can listen to 

the evidence in this case and decide the case based only on the evidence presented here in court and on my instructions as to the law.

The case is one that some of you—perhaps many of you—have heard about 

or read about. The defendants in this case are charged with participating in a conspiracy to provide support for various terrorist activities both here in the United 

States and abroad, as well as several counts of document fraud. I will have more 

to say about the charges in a moment.

We are not trying to nd people for this jury who have never heard of this 

case or of these charges. We are not even trying to nd jurors who have never 

held or expressed an opinion about these charges or about matters related to 

them. We are trying to nd jurors who—regardless of what they have seen or 

heard, and even regardless of what they have thought or said—can understand 

that their job as jurors is to decide this case based only on the evidence presented 

here in court, to apply only the legal rules that I explain and no others, and by 

applying those rules to that evidence, to determine whether or not each defendant’s guilt has been proved beyond a reasonable doubt. In other words, we are 

looking for people who can serve as fair, objective, and impartial jurors.

We are going to use the following procedure for jury selection: After I nish 

these preliminary remarks, which should take about 30 minutes, each of you will 

be given a questionnaire that contains certain questions for you to answer that 

will help us—the lawyers for the parties and me—to decide whether you can 

serve on this jury. As I will explain in more detail later on, after you nish lling 

out the questionnaire today you will submit it and go home, and then return on 

Tuesday, March 18, at which time some of you will be asked additional questions 

in person. We will use this process to get a panel of about 75 jurors. In addition 

to coming back on March 18, you may be asked to come back once or twice 

more during this selection process. From among this panel of 75 or so, the parties 

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United States v. Koubriti: Preliminary Voir Dire 

2 

will select 16 of you to serve as jurors and alternate jurors who will hear and decide the case. I hope, if everything goes smoothly, that we can get started with 

the trial itself later that week or early the following week.

The questions on the questionnaire and those we will ask in person ask certain facts about you and members of your family—whether you and any family 

members or close friends have any connection with the people or events underlying this case, whether you have opinions on certain subjects, and other matters, 

including how you are employed. I hope you understand that this is not an attempt to pry into your private life, but simply a way of helping all of us determine who can serve on this jury.

Before you are given the questionnaire to ll out, there are a few things I 

should explain about the case. The rst is the charges, which are contained in an 

indictment voted by a grand jury. An indictment is simply the document that contains the charges that the government is required to prove beyond a reasonable 

doubt, and, thereby, informs people of the charges against them so that they may 

defend themselves. In other words, it is the way that the government brings into 

court people whom the government claims have violated the law. That is the only 

function of an indictment in a criminal case. An indictment itself is not evidence 

of the guilt of any defendant. An indictment does not change in any way the presumption of innocence that the law gives every accused person at the start of a 

trial, a presumption that stays with the defendant throughout the trial unless and 

until the jury nds, in accordance with legal rules described by the court, that 

each and every element of a charge has been proven beyond a reasonable doubt.

The indictment in this case has four separate “counts” or charges. Count 1 

charges the defendants with participating in a conspiracy (which is simply a legal 

term for an unlawful agreement) to provide material support and resources to 

terrorists. In this charge, the government alleges that the object of the conspiracy 

was, among other things, to provide false documentation and identi cation materials, personnel, indoctrination, recruitment and training, target data collection, 

weapons, and other assistance for the purpose of engaging in violent attacks 

against persons and buildings within the United States and overseas—in Jordan 

and Turkey. Counts 2, 3, and 4 charge the defendants with conspiring and engaging in fraud and misuse of visas and other permits by obtaining and attempting to 

obtain false travel documents, passports, resident alien cards, social security 

cards, and drivers licenses for the purpose of disguising their own and other persons’ true identities.

As you can see from the description of the charges, this is a case in which 

people are charged with agreeing to commit criminal acts and with committing 

criminal acts. No one here is charged simply with having opinions or expressing 

ideas, neither of which is a crime in this country.

Further, none of the defendants here is charged with being involved with the 

events of September 11, 2001.

Each defendant, by entering a plea of not guilty in this case, has denied each 

of these charges, and the government has the obligation to prove the charges 

beyond a reasonable doubt.

I have just summarized these charges in a general way not for the purpose of 

describing what is necessary to prove them. The only purpose of summarizing 

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United States v. Koubriti: Preliminary Voir Dire 

3 

the charges at this point is so that you can understand the reasons for some of the 

questions you will be asked to answer on the questionnaire and later on during 

the jury selection process. Now that I have summarized the charges, I will introduce the lawyers who 

will be participating in the trial of this case. The government is represented in 

this case, as it is in all cases in which the government is a party before this court, 

by the United States Attorney for the Eastern District of Michigan. This case will 

be presented by Assistant United States Attorneys Richard Convertino and Keith 

Corbett.

I will now introduce the defendants’ lawyers and tell you who each lawyer 

represents. You will notice that some defendants may be represented by more 

than one lawyer, and you should draw no conclusion from that fact. The question 

of whether one or more lawyers represent a defendant is simply a matter of convenience and ef ciency and should not concern you. The rst defendant named 

in the indictment is Karim Koubriti. Mr. Koubriti is represented by Leroy Soles, 

Richard Helfrick, and James Gerometta. The next defendant is Ahmed Hannan. 

Mr. Hannan is represented by James Thomas. The third defendant is Abdel-Ilah 

Elmardoudi. He is represented by William Swor. The last defendant is Farouk 

Ali-Haimoud. He is represented by Robert Morgan.

Obviously, when you hear a lot of names and see a lot of faces, it is dif cult 

at rst to keep everyone straight. But, I can assure you that as the trial progresses 

you will have no dif culty keeping everyone’s identity straight. 

Now that I have introduced the parties and their lawyers, I should tell you a 

couple of additional facts about the case that may help you ll out the questionnaire and help you understand how the privacy of jurors can and will be preserved in a case like this in which there has been a good deal of public interest. 

Some of you may have heard or read about jurors being sequestered. The jury in 

this will not be sequestered. The jurors will go home every night. However, the 

names and addresses and other identifying information about jurors, such as their 

place of employment, will not be disclosed to anyone other than the jury clerk 

who will send each juror his or her check for jury service. That is to ensure that 

the privacy of jurors is preserved and that you are not contacted by the press or 

by others who may be curious about the case and want to talk to you about it. In 

addition, jurors will be picked up each morning by deputy U.S. Marshals at a 

convenient meeting place, or perhaps at several different places, and driven to the 

courthouse. While the jury is in the courthouse its members will remain with the 

marshals and will take their coffee breaks and meals together. Coffee and other 

refreshments, and lunch, will be provided by the court during the day for the jurors. In the evening, the jurors will be driven from the courthouse by the marshals 

back to a convenient drop-off point, or perhaps several drop-off points, and will 

make their way home. The jury will hear evidence in the case four days a week: 

Monday through Wednesday and Friday, at least initially. The jury will have 

Thursday off. I do not believe it will be necessary for us to go to a ve-day-aweek schedule, but I can’t promise that.

Perhaps I should say a few words about the security procedures in this case. 

When you came to the courthouse this morning you may have noticed that there 

are marshals and other security people posted inside and outside. The security 

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United States v. Koubriti: Preliminary Voir Dire 

4 

people are here simply to ensure that whatever people’s opinions or feelings may 

be about this case, they will not cause disruption of the trial, and that the jury can 

proceed in an orderly way to hear the evidence and decide the case based only on 

the evidence and on my instructions as to the law.

I am sure you are wondering how long the trial will take. Actually, I am 

wondering the same thing. It is not possible to predict with great accuracy how 

long it will take, but the best estimate I can make—and it is only an estimate—is 

that it will take between four and six weeks. I know that sounds like a long time, 

and there may be some of you who simply cannot take that amount of time to 

hear a case, even four days a week. I will discuss that later. But please understand 

that the lawyers and the court will do everything we can to present the case as 

quickly as possible, consistent with giving everyone here, both the defendants 

and the government, a fair trial. I should also tell you that after 30 days of trial, 

the jury fee you receive goes from $40 per day to $50 per day, so there is some 

slight additional compensation in a longer trial such as this. In addition, jurors 

will be paid their mileage—36¢ per mile—from your home to court and back.

You should also know that no one who is employed need be concerned about 

how their employer might react to their service on a jury during a lengthy trial. 

Most employers I think are pretty good and understanding about that, but in any 

event there is a federal statute that forbids any discrimination of any kind against 

anyone on account of jury service. I have made sure in the past that that statute 

was scrupulously observed by the employers of jurors who have served in this 

court, and you have my word that I will do so in this case. So you will not lose 

seniority or any other employment right as a result of your jury service. Although 

that statute does not require that an employer pay a person his or her salary during jury service, it does require that any employer who has a policy of paying 

employees during jury service continue to apply that policy.

During the trial, those who serve on the jury will have to agree not to read 

any of the newspaper or magazine reports about the case or to watch or listen to 

any radio or television news report about the case. This includes, of course, the 

Internet. I will discuss the reasons for that in greater detail later during and after 

the jury selection, but you can probably gure out the reasons for that yourselves. 

Those who are selected to serve on the jury will take an oath to decide the case 

based only on the evidence presented in court. There are two parts to that. First, it 

is the jurors who must decide the case for themselves, and second, they must do 

so based only on evidence received in court. If jurors read and are in uenced by 

news reports about the case, in effect they are surrendering their responsibility to 

news reporters or to people whose comments the reporters quote in the newspapers or on radio or television. Reporters frequently highlight only what is interesting and easy to understand. As you probably realize, not everything that is interesting and easy is necessarily important, and not everything that is important is 

necessarily interesting or easy. I believe most reporters try their best to “get it 

right.” But even when reporters try in good faith to get facts correct they are often working in a hurry with partial information, and they do not have an unlimited amount of space or time to explain the facts. To put it simply, even when 

media representatives try their best, they may not get it right or complete. And, 

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United States v. Koubriti: Preliminary Voir Dire 

5 

we do not want media reports—or anything else—to taint jurors’ views about the 

case.

Also, people may be quoted in news reports who have an interest in having 

the case come out one way or the other, and those people may say things they 

hope will in uence public opinion one way or the other. People with an interest 

in having the case come out one way or the other naturally will say what they 

think helps the side they want to help, and they will avoid discussing anything 

they think does not help their side. Needless to say, such statements are not evidence and cannot be considered by you. If a juror is in uenced by statements in 

press reports, which are not evidence and which the parties to this case do not 

have a chance to rebut or explain, then the juror is not being true to his or her 

oath to decide the case for himself or herself, and to decide it based on the evidence and not based on news reports. That is just a summary of the reasons why 

we do not want jurors being in uenced by news reports, and the easiest way not 

to be in uenced by news reports is not to see or hear them. Therefore, because 

you are now a prospective juror, please begin following this instruction today!

I am also instructing you that beginning today and on future days not to talk 

to anyone, including family and friends, about this case, and particularly not to 

reporters if they try to question you about it. Obviously I am also instructing the 

reporters not to try to question jurors or potential jurors because that could simply disqualify those jurors from service and would be interfering with the process 

of selecting a jury in this case. But although you will not be able to read about 

this case or hear about it from news reports, you should know that we will make 

available to the jurors at the courthouse the local daily newspapers with the stories about this case deleted, so you will be able to keep up with sports and with 

other important things.

I am almost done with these preliminary remarks and I thank you for your attention. A moment ago when I mentioned the projected length of the trial some 

of you looked uncomfortable. Others may feel that they would have dif culty 

serving because of the nature of the charges. I want to assure you that no one is 

going to be forced to serve on this jury who should not sit because he or she really cannot decide the case based only on the evidence but rather would be 

in uenced by other considerations, or who cannot sit because that person simply 

cannot afford the time away from business or other pressing matters. That is part 

of what we will be trying to nd out through the questionnaire. But I hope when 

you answer the questions on that questionnaire you will keep the following in 

mind: If you, or someone close to you, were accused of a crime, or were the victim of a crime, or were simply involved in an accident or some other event that 

caused a lawsuit, you would expect a group of your fellow citizens to put aside 

their beliefs and prejudices, and their other activities, for whatever time it took to 

hear your case; and you would have every reason to expect that, because it is 

your right in this country to expect it. The people involved in this case have a 

right to expect that as well. Also, each of you took an oath before we started that 

you would give truthful answers to all questions put to you touching upon your 

quali cations to serve as jurors. Everything that happens in this building—

indeed, in both our civil and criminal justice system—depends on people taking 

oaths seriously. No witness is allowed to testify until the witness takes an oath. 

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6 

Each of these lawyers took an oath before that lawyer was permitted to practice 

law, and a separate oath to practice in this court. I had to take an oath before I 

assumed my responsibilities as a federal judge. Your oath is no less important 

than the oaths of others who participate in this trial, and it applies to the questions 

on the questionnaire.

Just a few more words about the questionnaire. The form is about 25 pages 

long. Most of the questions are “Yes/No” questions, so you won’t have to sit and 

write any long answers. There are a few questions I should call to your attention. 

First, there is question 13, which asks for the city or township where you live and 

the city and state where you grew up. We are asking for the city or township and 

state only. Please do not put down the name of a village within a township, if you 

do live in a village. Again, just the township, not the village. Similarly, in questions 27 and 33 through 36, which ask questions about your education and employment, do not give the name of any schools or the names of any employers. 

Simply answer by way of the type of school and a description of your job.

As I mentioned, no one but the jury clerk will know the identity of the jurors. 

Each of you has been given a juror number. That number should go on the form 

in the designated space. Please do not put your name anywhere on the form. The 

only person who has a list of the names corresponding to the numbers you have 

is the jury clerk who will issue the checks to the jurors for their jury service, so 

the lawyers and others who will get copies of the questionnaire to review will not 

know the name or other identifying information about jurors. And, when you return here on March 18, do not wear anything with your monogram on it and do 

not bring with you any magazines with address labels on them or any books with 

your names or addresses on them. You should also remember to address each 

other by your rst names only. Our goal in giving you these instructions is to protect your rights of privacy.

After you have nished lling out the questionnaire, you may give it to the 

clerk, who will make sure that it is complete and that your number appears in the 

proper place. You may then go home. We will ask you to return on March 18 to 

the jury room. You will then be told whether you will be asked any further questions as part of the remainder of the jury selection process. Those who are to be 

questioned further will meet with me and the lawyers and the defendants in my 

courtroom. After that we will pick about 45 jurors at random, and they may be 

asked some additional questions. From this group we will select the 16 jurors 

who will hear and decide this case.

Importance of Jury Service

I will now turn this over to the jury clerks who will hand out the questionnaires. 

When you are done, you will turn your questionnaire in to one of the clerks who 

will review the form to make sure it is complete. You are then free to leave.

Once again, thank you for your attention. Have a pleasant day and a safe trip 

home.

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1 

United States v. Koubriti:

Jury Questionnaire

Hon. Gerald E. Rosen

Eastern District of Michigan

March 18, 2003

The following questionnaire was prepared to facilitate jury selection in a highprofile prosecution of suspected terrorists, United States v. Koubriti, No. 2:01-cr- 80778 (E.D. Mich. Sept. 27, 2001).

Cover Letter

21 February 2003

Dear Jurors,

The furnishing of information on this questionnaire is designed to expedite 

the jury-selection process in this case. If you have any inquiries concerning any 

particular question, please ask the Court and it will be explained to you. Most of 

the questions ask you to simply answer “yes” or “no” and sometimes to explain 

your answers further in the space provided. If you need more space to answer the 

question, use the blank “Explanation Sheet” at the end of the questionnaire.

The Court is aware that some of the questions contained in this questionnaire 

are of a somewhat personal nature. Nonetheless, the Court must ensure that the 

jury that hears this case can be completely fair to both sides and that both sides 

have sufficient information about each juror’s background and experiences that 

they can feel comfortable that a fair and impartial jury will hear this case. Please 

be completely frank and candid in responding to this questionnaire. Please do 

not discuss the questionnaire or your answers, or any issues raised by the 

questionnaire, with anyone, including family members or friends. It is very 

important that the answers be yours and yours alone. Remember that there are no 

“right” or “wrong” answers—only truthful answers. You are sworn to give true 

and complete answers to all questions.

Your answers will not become public and, indeed, the Court and parties will 

not even know your name. Selecting an anonymous jury is not an unusual practice and has been followed in many cases in Federal Court. Anonymity will ward 

off curiosity that might infringe on a juror’s privacy. Please write only your juror number, and not your name, on the first page of the questionnaire.

I appreciate your time and dedication in assisting the Court in the administration of justice.

Gerald E. Rosen

United States District Judge

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United States v. Koubriti: Jury Questionnaire

2 

Jury Questionnaire

A. Case Information

1. The Court and the parties estimate that after a jury is selected this case will 

last approximately 4 to 6 weeks. It is anticipated that the jury in this case will 

be sitting 4 days per week: Monday, Tuesday, Wednesday, and Friday, 9:00 

a.m. to 5:00 p.m. If, however, it becomes necessary, we may have to sit 5 

days per week. Jury service is one of the highest duties and privileges of a 

citizen. Mere inconvenience or the usual financial hardships of jury service 

will be insufficient to excuse a prospective juror. Do you wish to apply to the 

Court to be excused on the ground that jury service in this case would be an 

extreme hardship? _____________ Yes ____________ No If yes, briefly explain the hardship: (Note: If the hardship claimed is financial, please do not name your employer, but merely describe in general terms the nature of the situation.) _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 2. The Government is represented in this case by the United States Attorney, 

Jeffrey Collins, though the conduct of the case is in the immediate charge of 

the Government attorneys appearing in the courtroom. Do you or does any 

relative or close friend of yours know or have any connection with Jeffrey 

Collins? _____________ Yes ____________ No

3. Do you or does any relative or close friend of yours know or have any connection with any of the following persons who will be seated at the counsel 

table for the Government? Assistant United States Attorney Richard G. Convertino ____ Yes __ No

Assistant United States Attorney Keith E. Corbett ____ Yes __ No

FBI Special Agent Michael Thomas ____ Yes __ No (a) Have you seen, heard, or read anything about any of these individuals? 

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

heard from friends, relatives, or co-workers. _____________ Yes ____________ No

(b) If yes, what have you seen, heard, or read? _______________________

_________________________________________________________

_________________________________________________________ 

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3 

4. (a) Do you or does any relative or close friend of yours know or have any 

connection with any of the defendants? Karim Koubriti ______ Yes ______ No 

Ahmed Hannan ______ Yes ______ No 

Abdel-Ilah Elmardoudi

a/k/a Abdella

a/k/a Nassim Hillali

a/k/a Hussein Mohsen Safiddine

a/k/a Abdelilah El Mardoudi

a/k/a Abdell Illah Naji

a/k/a Nelson R. Feliciano

a/k/a Nelson Rafael Feliciano Vargas

a/k/a Nelson R. Feliciano Vargas

a/k/a Nelson R. Falecian

a/k/a Jean Pierre Tardelli

a/k/a George Labibe

a/k/a Hussein Mohsen Safiddine

a/k/a Nabit Hayamm ______ Yes ______ No 

Farouk Ali-Haimoud

a/k/a Khalid ______ Yes ______ No (b) Have you seen, heard, or read anything about any of the defendants? 

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

from friends, relatives, or co-workers. _____________ Yes ____________ No

(c) If yes, what have you seen, heard, or read? _____________________

________________________________________________________

________________________________________________________ 

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4 

5. (a) Do you or any relative or close friend of yours know of, or have any 

connection with, any of the following defense lawyers or their staffs? Attorneys

Richard M. Helfrick ______ Yes ______ No 

Leroy T. Soles ______ Yes ______ No 

James C. Thomas ______ Yes ______ No 

Robert M. Morgan ______ Yes ______ No 

William W. Swor ______ Yes ______ No 

Kevin S. Ernst ______ Yes ______ No 

Heather L. Bendure ______ Yes ______ No 

Stephen T. Rabaut ______ Yes ______ No Private Investigators

David Gentry ______ Yes ______ No 

Suzanne Zanon ______ Yes ______ No 

Huntington Research Associates ______ Yes ______ No Interpreters

Nazih Moakiel ______ Yes ______ No 

Frank Nalu ______ Yes ______ No 

Alex Daghestani ______ Yes ______ No 

Elsayed Ibrahim ______ Yes ______ No 

El Sayed Mostafa ______ Yes ______ No 

David Habboo ______ Yes ______ No 

Salim Mansour Habboo ______ Yes ______ No 

Bassani Shamurad ______ Yes ______ No 

Access Languages ______ Yes ______ No If you answered “yes” to any of the names above, describe your connection with these individuals: _______________________________

________________________________________________________

________________________________________________________ (b) Have you seen, heard, or read anything about these attorneys or the 

members of their staffs? This includes not only from the media, but also anything you may have heard from friends, relatives, or co-workers. _____________ Yes ____________ No

(c) If yes, what have you seen, heard, or read? _____________________

________________________________________________________

________________________________________________________ 

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5 

6. (a) Do you or any relative or close friend of yours know of or have any 

connection with any of the individuals listed on “Attachment A” [omitted] who may be a witness or who may be mentioned at trial? _____________ Yes ____________ No

(b) If you have any such connection with any of the individuals on Attachment A, please list the individual’s name here and explain the connection. (If you need extra space, use the “Explanation Sheet” at the 

end of this questionnaire.) ________________________________________________________

________________________________________________________

________________________________________________________

________________________________________________________

________________________________________________________

________________________________________________________

________________________________________________________

________________________________________________________ (c) Have you seen, heard, or read anything about these individuals? This 

includes not only from the media, but also anything you may have 

heard from friends, relatives, or co-workers. _____________ Yes ____________ No

(d) If yes, what have you seen, heard, or read? _____________________

________________________________________________________

________________________________________________________

________________________________________________________ 7. This case is about allegations of fraud and misuse of visas, permits, and other 

identification documents, and providing material support or resources to terrorists. Have you read, seen, or heard anything about this case? _____________ Yes ____________ No If yes, what was the source of the information (radio, TV, newspaper, etc.)? ____________________________________________________________

_____________________________________________________________ 8. If you have seen, heard, or read something about this case, any of the defendants or attorneys, or witnesses, is there anything about what you have heard, 

seen, or read that would prevent you from rendering a fair and impartial verdict based solely on the evidence presented in court? _____________ Yes ____________ No

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United States v. Koubriti: Jury Questionnaire

6 

9. The judge who will preside over this case is the Honorable Gerald E. Rosen 

of the United States District Court for the Eastern District of Michigan. The 

members of Judge Rosen’s staff are: Donna Vinson, Sara Fischer-Hodges, 

Linda Hylenski, Jim Lewis, and Carol Sapala. Do you or any of your relatives or close friends know or have any connection with Judge Rosen or any 

of his staff? _____________ Yes ____________ No If yes, please explain. ___________________________________________

_____________________________________________________________

_____________________________________________________________ B. Personal and Family Information

10. Your juror number: _________ 11. Your age: ________ 12. Your sex: _______Male ________ Female 13. Address information: a. City or township where you live: _____________________________ b. Number of years there: _____________________________________ c. Do you own _______ rent _______ or live with others? _______ d. City or town and state where you grew up: ______________________ 14. Your present marital status: ________ Married ________ Single (never married) ________ Widowed ________ Separated or divorced 15. Are you, your spouse, or a former spouse a naturalized U.S. citizen? _____________ Yes ____________ No If yes, please state who and when they became a citizen. _______________

_____________________________________________________________ 16. Where were your parents born? Mother ________________________________________ Father _________________________________________ 

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United States v. Koubriti: Jury Questionnaire

7 

17. Are your parents, in-laws, or grandparents naturalized U.S. citizens? _____________ Yes ____________ No If yes, please state your relationship to each person (e.g., “mother-in-law”) 

and when (if you know) he or she became a citizen. ___________________

_____________________________________________________________

_____________________________________________________________ 18. 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. ___________________________________________

_____________________________________________________________

_____________________________________________________________ 19. Do you have any friends or relatives who live on Riverside in Dearborn, or 

on Norman Street in Detroit? _____________ Yes ____________ No If yes, who are these friends/relatives? _____________________________

_____________________________________________________________

_____________________________________________________________ 20. (a) How many years have you lived in Southeast Michigan? __________ (b) Have you ever lived outside of the United States? If so, where? _____

________________________________________________________ 21. Do you have children? _______ If yes, state the age of each child. ____________________________________________________________

_____________________________________________________________

_____________________________________________________________ 22. Do you have any physical problems or disabilities involving high blood pressure, hearing or vision loss, stomach ailments, headaches, back, hip or neck 

problems, or any other health problems that might interfere with your ability 

to serve as a juror or may cause you difficulty in hearing, seeing, or understanding evidence in a trial? Please explain. _____________________________________________________________

_____________________________________________________________

_____________________________________________________________ 

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United States v. Koubriti: Jury Questionnaire

8 

(a) Do you have any specific problems dealing with stress or pressure? _____________ Yes ____________ No If yes, please explain. _____________________________________

________________________________________________________

________________________________________________________ (b) Have you ever had any psychological therapy or counseling? _____________ Yes ____________ No

If yes, please explain. ______________________________________

________________________________________________________

________________________________________________________ (c) Have you ever been under a doctor’s care for any of the following: (1) Mental problems, including mood disorders 

 ______ Yes _______ No 

(2) Alcohol-related problems 

 ______ Yes _______ No 

(3) Drug-related problems 

 ______ Yes _______ No If you answered “yes” to 22(c)(1), (2), or (3), please explain. ____________

_____________________________________________________________

_____________________________________________________________ 23. Are you taking any medication that might interfere with your ability to serve 

as a juror? If so, please explain. ___________________________________

_____________________________________________________________

_____________________________________________________________

_____________________________________________________________ 24. Do you have any difficulty reading or understanding English? _____________ Yes ____________ No

25. Do you have a vacation scheduled for which you have prepaid or made a financial commitment? If so, please explain. __________________________

_____________________________________________________________

_____________________________________________________________

_____________________________________________________________ 

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United States v. Koubriti: Jury Questionnaire

9 

26. How far would you have to travel each day to attend trial? ______ miles one way. B. Education

27. What is the highest grade that you completed in school? Circle the appropriate answer: 1–7 8 9 10 11 12 College: 1 yr. 2 yrs. 3 yrs. 4 yrs. Vocational/technical school: 1 yr. 2 yrs. 3 yrs. 4 yrs. Graduate/professional school—specify: ____________________________ 28. If you did not graduate from high school, did you obtain a G.E.D.? _____________ Yes ____________ No

29. If you continued your education beyond high school, what was (were) your 

major area(s) of study? __________________________________________

_____________________________________________________________

_____________________________________________________________ 30. What degrees have you earned? ___________________________________

_____________________________________________________________ C. Employment

31. Are you the sole source of income for your immediate family? _____________ Yes ____________ No

32. If you are not employed, are you: ______ a student: 

Where do you attend school? ________________________ How many days per week? __________________________ ______ a homemaker ______ between jobs ______ disabled ______ retired 

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United States v. Koubriti: Jury Questionnaire

10

33. If you are now employed, please describe your job (do not name your employer): Job description: _______________________________________________ Years in this job: ______________________________________________ 34. If you have not been employed with your current employer for more than one 

year, please describe your last job prior to your current job: Job description: _______________________________________________ Years in this previous job: _______________________________________ 35. If you are married, please describe your spouse’s current job: Job description: _______________________________________________ Years in this job: ______________________________________________ 36. If you have children who are now employed, please describe their current 

job(s): Job description Years in this job

37. Do you have any relatives or close friends who are employed by Detroit Metropolitan Airport or LSG Sky Chefs ? _____________ Yes ____________ No If yes, please explain. ___________________________________________

_____________________________________________________________

_____________________________________________________________ 

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United States v. Koubriti: Jury Questionnaire

11

D. Other Personal/Family Information

38. Have you or any member of your immediate family ever served in the military (including the National Guard and the military reserves)? _____________ Yes ____________ No Please describe the nature of any such military service by you or any member 

of your immediate family, including the dates of service, branch of the military, rank, and duties. ___________________________________________

_____________________________________________________________

_____________________________________________________________

_____________________________________________________________ 39. If any members of your family are currently in the military, are any of them 

currently deployed/stationed overseas? If yes, please explain. ___________

_____________________________________________________________

_____________________________________________________________ 40. If you or a member of your family served in the military, were they ever in a 

combat situation? Yes _____ No _____ Don’t know 

 

If yes, please state where and when. _______________________________

_____________________________________________________________

_____________________________________________________________ 41. Did you or any member of your family serve in “Desert Storm”? If yes, 

please explain. ________________________________________________

_____________________________________________________________

_____________________________________________________________ 42. Do you have any relatives or close friends in the military who are currently 

or were formerly stationed in Afghanistan or elsewhere in the Middle East? _____________ Yes ____________ No If yes, where is or was that person stationed? ________________________

_____________________________________________________________

_____________________________________________________________ 43. Have any relatives or close friends been injured or killed while serving in a 

combat or military zone in Afghanistan or elsewhere in the Middle East? _____________ Yes ____________ No

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United States v. Koubriti: Jury Questionnaire

12 

44. Have you or any members of your family had any experience in military or 

civilian intelligence? _____________ Yes ____________ No If yes, please explain. ___________________________________________

_____________________________________________________________

_____________________________________________________________ 45. Were you or any members of your family ever involved in a court martial? _____________ Yes ____________ No If yes, please explain. ___________________________________________

_____________________________________________________________

_____________________________________________________________ 46. Do you or did you have family members or close friends who were the victims of terrorism in this country or abroad? If yes, please explain. ________

_____________________________________________________________

_____________________________________________________________

_____________________________________________________________

_____________________________________________________________ 47. Have you or any relative or close friend of yours been to “Ground Zero,” the 

site of the World Trade Center, since September 11, 2001? _____________ Yes ____________ No 48. Have you or anyone close to you altered your travel plans since September 

11, 2001? _____________ Yes ____________ No 49. Is there anything in particular about a case involving a charge of terrorism 

that would make it difficult for you to serve as a fair and impartial juror in 

this case? _____________ Yes ____________ No 

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United States v. Koubriti: Jury Questionnaire

13

50. If you answered any of the questions 47 through 49 “yes,” please explain. _____________________________________________________________

_____________________________________________________________

_____________________________________________________________ E. Media

51. Do you or your family regularly subscribe to any magazines or newspapers? _____________ Yes ____________ No If yes, please list the magazines and newspapers you or your family have 

subscribed to in the last five years. ________________________________

_____________________________________________________________

_____________________________________________________________ 52. Do you read a newspaper regularly (at least two or three times a week)? _____________ Yes ____________ No

If yes, list the names of the newspapers you read and indicate how often you 

read each newspaper. Name of 

paper

Once a 

week

2–3 times 

a week

More than 

4x a week Daily

Sunday 

only

53. Do you regularly read magazines? _____________ Yes ____________ No If so, please list the magazine titles that you read when you have the opportunity. _______________________________________________________

_____________________________________________________________ 54. What types of books do you like to read? ___________________________

_____________________________________________________________

_____________________________________________________________ 55. List the last three books that you have read. _________________________

_____________________________________________________________ 56. What kinds of movies do you like? ________________________________

_____________________________________________________________ 

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United States v. Koubriti: Jury Questionnaire

14

57. Do you watch any television newscasts, including cable newscasts, on a 

regular basis? _____________ Yes ____________ No If yes, which ones? _____________________________________________

_____________________________________________________________ 58. Do you listen to any radio stations on a regular basis? _____________ Yes ____________ No If yes, which ones? _____________________________________________

_____________________________________________________________ 59. This case may receive media attention. The Court wants to make sure that 

this case is decided solely on the evidence presented 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 on the Internet, 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

F. Leisure Activities

60. Do you have any hobbies? _____________ Yes ____________ No If yes, please describe them. ______________________________________

_____________________________________________________________

_____________________________________________________________ 61. What activities do you particularly enjoy if you have leisure time available? _____________________________________________________________

_____________________________________________________________

_____________________________________________________________ 

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United States v. Koubriti: Jury Questionnaire

15

62. Do you own or regularly use a computer? _____________ Yes ____________ No

If yes: (a) Explain your use of the computer. ____________________________ ________________________________________________________ ________________________________________________________ (b) What Internet websites do you regularly access? _________________ ________________________________________________________ ________________________________________________________ G. Associations/Affiliations

63. Do you belong to a union, professional organization, religious organization, 

social or fraternal organization or society, or civic club? _____________ Yes ____________ No If so, please state the general nature of any such organization(s) (e.g., union, 

service club, PTA, etc.). _________________________________________

_____________________________________________________________

_____________________________________________________________ 64. Do you have a religious preference? _____________ Yes ____________ No If yes, please state the name of the church, temple, synagogue, mosque, or 

other religious organization with which you are affiliated. ______________

_____________________________________________________________

_____________________________________________________________ 65. How often do you attend religious services? _________________________

_____________________________________________________________ 66. Do you participate in other religious activities? _____________ Yes ____________ No If yes, please describe. __________________________________________

_____________________________________________________________ 

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United States v. Koubriti: Jury Questionnaire

16

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

because of your religious beliefs? _____________ Yes ____________ No If yes, please explain. ___________________________________________ _____________________________________________________________

_____________________________________________________________ 68. Do you know anyone who practices the Muslim or Islamic faith? _____________ Yes ____________ No

69. Do you have any feelings, positive or negative, about the Muslim or Islamic 

faith? Please explain. ___________________________________________ _____________________________________________________________ _____________________________________________________________ 70. How knowledgeable are you about the history or practices of the Muslim or 

Islamic faith? ______ very knowledgeable ______ somewhat knowledgeable ______ not too knowledgeable ______ not knowledgeable at all 71. Is there anything about a case where all the defendants are Muslim (which 

means they practice Islam) that would make it hard for you to serve as a juror? _____________ Yes ____________ No If yes, please explain. ___________________________________________

_____________________________________________________________

_____________________________________________________________ 72. Have you ever heard the word “Jihad”? _____________ Yes ____________ No If yes, what does it mean to you? __________________________________

_____________________________________________________________ 73. Do you contribute services or money to any charitable organization? If so, 

please describe. _______________________________________________

_____________________________________________________________ 

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United States v. Koubriti: Jury Questionnaire

17

74. Have you ever contributed money to an organization that opposes immigration, or opposes certain rights to immigrants, or proposes changes to the immigration laws? _____________ Yes ____________ No If yes, please explain. ___________________________________________

_____________________________________________________________

_____________________________________________________________ H. Foreign Nationals

75. (a) Do you speak Arabic (or any dialect of Arabic) or did you grow up in 

households where the Arabic language or any of its dialects were spoken? _____________ Yes ____________ No

(b) Do you read any Arabic language newspapers or publications? _____________ Yes ____________ No If yes, please list the Arabic language newspapers or publications. ___

________________________________________________________

________________________________________________________ (c) Do you watch any Arabic language television programs, including 

newscasts? _____________ Yes ____________ No If yes, please list these programs/newscasts. ____________________

________________________________________________________

________________________________________________________ (d) If you speak, read, or understand the Arabic language (or any of its dialects), would you have any difficulty relying upon the official interpreter’s translation of testimony and witnesses’ translations of Arabic language evidence? _____________ Yes ____________ No

(e) What other languages, if any, do you speak or understand? _________

________________________________________________________

________________________________________________________ 

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United States v. Koubriti: Jury Questionnaire

18

76. Are you familiar with the culture, politics, or economy of any of the countries in the Middle East? If so, please explain. ________________________ _____________________________________________________________ _____________________________________________________________

_____________________________________________________________ 77. The defendants in this case are of Moroccan, Algerian, Arabic, or Middle 

Eastern descent. (a) Are you, or any of your relatives or close friends, of Moroccan, Algerian, Arabic, or Middle Eastern descent? _____________ Yes ____________ No

(b) Do you work, or have you worked, with persons of Moroccan, Algerian, Arabic, or Middle Eastern descent? _____________ Yes ____________ No

(c) Do you socialize with any people of Moroccan, Algerian, Arabic, or 

Middle Eastern descent? _____________ Yes ____________ No

(d) Do you have an initial reaction when learning that a person is of Arabic 

nationality or Middle Eastern origin ? _____________ Yes ____________ No If you answered “yes” to (a), (b), (c), or (d), please explain. _____________

_____________________________________________________________

_____________________________________________________________ 78. Have you had, or do you know of any relative or friend who has had any 

dealings with the Arab Community Center for Economic and Social Services 

(ACCESS)? _____________ Yes ____________ No If yes, please explain. ___________________________________________

_____________________________________________________________

_____________________________________________________________ 

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United States v. Koubriti: Jury Questionnaire

19

79. Have you worked in, traveled in, read about, or formed impressions or opinions about any of the following countries? Morocco Afghanistan Saudi Arabia

Algeria Yemen Egypt

Jordan Iraq Arab Emirates

Turkey Iran Israel

Syria Sudan Palestine

Kuwait Libya _____________ Yes ____________ No If yes, please explain. (Use the Explanation Sheet at the end of the questionnaire if necessary.) _____________________________________________

_____________________________________________________________

_____________________________________________________________ I. Law/Law Enforcement

80. Have you ever served as a juror? _____________ Yes ____________ No

If yes, please list below: (1) the approximate date(s); (2) whether it was in a 

state or federal court; (3) whether it was a criminal or civil case; (4) the general nature of the case (e.g., robbery, murder, negligence, medical malpractice, breach of contract, etc.); (5) whether a verdict was reached; and (6) if a 

verdict was reached, what was the verdict? Date

State or 

federal 

court

Criminal 

or civil 

case

Nature of 

case

Was there 

a verdict?

What 

was the 

verdict?

81. Have you ever served as a grand juror? _____________ Yes ____________ No 

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United States v. Koubriti: Jury Questionnaire

20

82. Have you or any close friends or relatives had any education or training in 

the law? _____________ Yes ____________ No If yes, please explain. ___________________________________________ _____________________________________________________________

_____________________________________________________________ 83. Have you or any member of your family every worked in any law-related 

profession (e.g., attorney, paralegal, legal assistant, legal secretary, clerk, 

etc.)? _____________ Yes ____________ No If yes, please explain. ___________________________________________ _____________________________________________________________

_____________________________________________________________ 84. Have you ever been employed by, connected with, or applied for a job in law 

enforcement? _____________ Yes ____________ No If yes, please explain. ___________________________________________ _____________________________________________________________

_____________________________________________________________ 85. Have any family members every been employed in law enforcement? _____________ Yes ____________ No If yes, please explain. ___________________________________________ _____________________________________________________________

_____________________________________________________________ 86. 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 yes, please explain. ___________________________________________ _____________________________________________________________

_____________________________________________________________ 

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United States v. Koubriti: Jury Questionnaire

21

87. Do you belong to or associate with any groups that have crime prevention or 

law enforcement as a goal? _____________ Yes ____________ No If yes, please explain. ___________________________________________ _____________________________________________________________

_____________________________________________________________ 88. Are you a member or supporter of any group that is either for or against gun 

control (such as the National Rifle Association)? _____________ Yes ____________ No If yes, please list the organizations. ________________________________ _____________________________________________________________ 89. Do you or anyone in your house own any firearms? _____________ Yes ____________ No If yes, what type and for what purpose? _____________________________ _____________________________________________________________ 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 

each juror (or their loved ones) 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 this case. Please do not 

feel embarrassed about any question, because the answers will be strictly confidential. 90. Have you or anyone close to you ever been charged with a crime or been the 

subject of a criminal investigation? _____________ Yes ____________ No If yes, please explain. ___________________________________________ _____________________________________________________________

_____________________________________________________________ 

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United States v. Koubriti: Jury Questionnaire

22

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

proceeding? _____________ Yes ____________ No If yes, please explain. ___________________________________________ _____________________________________________________________

_____________________________________________________________ 92. Are you, or anyone close to you, now under subpoena or, to your knowledge, 

about to be subpoenaed in any criminal case? _____________ Yes ____________ No If yes, please explain. ___________________________________________ _____________________________________________________________

_____________________________________________________________ 93. 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 an 

United States investigative agency such as the FBI, Drug Enforcement Administration (DEA), Internal Revenue Service (IRS), Immigration and Naturalization Service (INS), or Customs Service ? _____________ Yes ____________ No If yes, please explain. ___________________________________________ _____________________________________________________________

_____________________________________________________________ 94. Have you ever been involved in, or do you expect to become involved in, any 

legal action or dispute with the United States or any agency, officer, or employee of the United States, or have you ever had any financial interest in 

such a dispute? _____________ Yes ____________ No If yes, please explain. ___________________________________________ _____________________________________________________________

_____________________________________________________________ 

322 322
United States v. Koubriti: Jury Questionnaire

23

95. Have you or has any member of your family or a close friend ever been the 

victim of crime? _____________ Yes ____________ No If yes, please explain. ___________________________________________ _____________________________________________________________

_____________________________________________________________ 96. Have you or has any member of your family or a close friend ever had any 

identification stolen, such as a license, credit card, passport, or visa, or been 

the victim of “identity theft”? _____________ Yes ____________ No If yes, please explain. ___________________________________________ _____________________________________________________________

_____________________________________________________________ 97. Have you or has any member of your family or a close friend ever been falsely accused of anything? _____________ Yes ____________ No If yes, please explain. ___________________________________________ _____________________________________________________________

_____________________________________________________________ 98. 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 (circle one): a. more likely to tell the truth than other witnesses

b. about as likely to tell the truth as other witnesses

c. less likely to tell the truth than other witnesses 99. You may hear testimony in this case concerning the use of informants and/or 

cooperating witnesses by federal authorities in their investigations. One or 

more of those individuals may be called to testify in this case and you may 

learn that some of the individuals have participated in various crimes. Do you 

have any strong feelings about the government using informants and/or cooperating witnesses? _____________ Yes ____________ No If yes, please explain. ___________________________________________ _____________________________________________________________

_____________________________________________________________ 

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United States v. Koubriti: Jury Questionnaire

24 

100. 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. _________________________________________ ___________________________________________________________

___________________________________________________________ 101. There may also be evidence seized pursuant to searches of various places, 

including the homes of some of the defendants. Do you have any feelings 

about the use of lawfully conducted searches? _____________ Yes ____________ No If yes, please explain. _________________________________________ ___________________________________________________________

___________________________________________________________ 102. To your knowledge, have you or any close friend or relative ever been the 

subject of a 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. _________________________________________ ___________________________________________________________

___________________________________________________________ 103. Is there any matter not covered by this questionnaire that you feel you 

should tell us about? _____________ Yes ____________ No If yes, please explain. _________________________________________ ___________________________________________________________

___________________________________________________________ 

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United States v. Koubriti: Jury Questionnaire

25

Explanation Sheet 

325
 

1 

United States v. El-Hage:

Jury Questionnaire

Hon. Leonard B. Sand

Southern District of New York

January 3, 2001

The following questionnaire was prepared by the Southern District of New 

York’s United States District Judge Leonard B. Sand to facilitate jury selection in 

the prosecution of Mohammed Odeh, Mohamed al-’Owhali, Wadih el-Hage, and 

Khalfan Khamis Mohamed for killing American citizens by bombing American 

embassies in Kenya and Tanzania on August 7, 1998, in United States v. ElHage, No. 1:98-cr-1023 (S.D.N.Y. Sept. 21, 1998).

General Instructions

This questionnaire is designed to help simplify and expedite the jury selection 

process. 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.

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 

that the answers be yours alone. Remember, you are sworn to give true and complete answers to all questions. After reading your questionnaire, Judge Sand will 

personally interview you and give you the opportunity to discuss your answers.

During your jury service, the judge and the parties will not know your name. 

They will know you only by your juror number. Selecting an anonymous jury is 

not an unusual practice and has been followed in many cases in federal court. 

Anonymity will deter curiosity that might infringe on your privacy. Accordingly, 

do not reveal any information in the questionnaire that could be used to identify 

you, such as your employer’s name or your address.

Use black pen only. Blue ink will not copy. You may borrow a black pen if 

necessary.

Write your juror number at the top of this page.

Do not write on the back of any page; only the front pages will be copied. If 

you need additional space to complete an answer, go to the blank pages at the 

back of the questionnaire, indicate the number of the question, and continue your 

answer.

Hardship Question

The Court and the parties estimate that the trial in this case will last approximately nine to twelve months. It is anticipated that the jury will sit four days per week 

during the bulk of the trial, when evidence is being taken, although the jury will 

have to be present five days a week during jury selection, opening and closing 

statements, and deliberations. Thus, for most of the trial jurors will not be re326 326
United States v. El-Hage: Juror Questionnaire 2 

quired to report on Fridays or holidays. If possible, the court plans to adjourn for 

a one-week recess in August. In addition, every effort will be made to accommodate special needs of individual jurors. Jurors will be paid an attendance fee of 

$40 per day for the first 30 days of trial and $50 per day thereafter. Lunch will be 

provided daily, and your 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.

Would you have a serious hardship if chosen for this case? ____ Yes, I would have a serious hardship if chosen for this case. Please answer the questions below and fully explain your hardship. You must still 

complete the entire questionnaire. ____ No, I would not have a serious hardship if chosen for this case. Please 

move on to the next section of the questionnaire.

If yes, please explain the hardship and list your current occupation. Describe the 

type of job and business without giving details of your employer’s name or address. For example, simply list “receptionist,” “business executive,” “school 

teacher,” or “self-employed/freelance.” If you are retired or unemployed, please 

indicate that fact and list your previous occupation. Please write legibly.

Occupation: ______________________________________ Your age: _______ Are you self-employed? _______________ Are you retired? _______________ Will you be paid your salary while you serve jury duty? ___________________ What is your hardship? _____________________________________________ ________________________________________________________________ ________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________ Description of the Case

In this case there are four defendants, two of whom face the death penalty. All 

four defendants are charged in an indictment with having been part of a conspira327
United States v. El-Hage: Juror Questionnaire 3 

cy to commit various acts of terrorism and with committing certain federal 

crimes, including murder, attempted murder, the bombing of federal buildings, 

perjury, and making false statements to federal law enforcement officers. Specifically, the defendants are charged variously with crimes relating to an alleged 

agreement to kill American citizens, which resulted in the bombings of the United States embassies in Nairobi, Kenya, and Dar es Salam, Tanzania, on August 7, 

1998. In the bombing in Tanzania, 11 people were killed and approximately 70 

were injured. In the bombing in Kenya, 223 people were killed and thousands of 

people were injured.

The organization with which the defendants were allegedly associated is 

called “al-Qaeda,” or the “Base,” which the Government charges was engaged in 

international terrorism. While other people were allegedly involved, only four 

defendants are on trial in this case. Each of the accused is entitled to separate 

consideration, and the case against each person must be decided individually.

The Nature of an Indictment

An indictment is merely an accusation. It is proof of nothing. You may draw no 

inference against any defendant from the fact that he has been indicted. Each defendant has pleaded “not guilty” to each of the charges against him and is presumed to be innocent. A defendant does not have to prove anything. The government bears the burden of proving the guilt of a defendant beyond a reasonable 

doubt.

Personal Background

1. What is your age? __________

2. Are you: male _____ female _____

3. Do you have any problem with your hearing or vision that would make it 

difficult for you to serve as a juror? Yes _____ No _____

4. Do you have any medical condition that would make it difficult for you to 

serve as a juror on this case? Yes _____ No _____

5. Are you taking any prescription medication that may interfere with your 

ability to concentrate or serve as a juror in any way? Yes _____ No _____

6. Have you recently been treated for a substance abuse problem (for example, alcohol or illegal or prescription drugs)? Yes _____ No _____

328 328
United States v. El-Hage: Juror Questionnaire 4 

7. What is your place of birth? (Please list only the city and state, and, if outside the United States, the country.) ___________________________________________________________ 8. Are you? Married _____

Single _____

Living with another person as a couple _____

Divorced/Separated _____

Widow/Widower _____

9. What is your ethnic background? ___________________________________________________________ (a) If married, what is the ethnic background of your spouse? _____________________________________________________ 10. What county do you live in? ____________________________________ (a) If you live in New York City, what neighborhood do you live in? 

(For example: Upper West Side, Morrisania, Throgs Neck.) Do not 

give your address. _____________________________________________________ (b) If you live in a suburban county, what part of the county do you live

in (north or south)? _____________________________________________________ 11. Do you read a newspaper regularly (at least two or three times a week)? Yes _____ No _____ If yes, list the names of the newspapers you read and indicate how often 

you read each newspaper.

Name of 

Newspaper

Once a 

week

2–3 

times a 

week

More 

than 4x 

a week Daily

Sunday 

only

 

12. What magazines or periodicals do you read? ___________________________________________________________ 

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United States v. El-Hage: Juror Questionnaire 5 

13. Do you watch any television newscasts on a regular basis? Yes _____ No _____ If yes, which ones? ___________________________________________________________ 14. Do you listen to any radio stations on a regular basis? Yes _____ No _____ If yes, which ones? ___________________________________________________________ 15. Is English your first language? Yes _____ No _____

16. What other languages do you speak, read, or understand? ___________________________________________________________ 17. Where were your parents born? Mother _________________________________ Father __________________________________ 18. Are you, your spouse, or a former spouse a naturalized U.S. citizen? Yes _____ No _____ If yes, please tell us who and when the person became a citizen? ___________________________________________________________ 19. Are your parents, in-laws, or grandparents naturalized U.S. citizens? Yes _____ No _____ If yes, please tell us your relationship to that person (for example, “mother-in-law”) and when (if you know) the person became a citizen. ___________________________________________________________ 

330 330
United States v. El-Hage: Juror Questionnaire 6 

20. Do you speak Arabic (or any dialect of Arabic), or did you grow up in 

households where the Arabic language or any of its dialects were spoken? Yes _____ No _____

(a) Do you read any Arabic language newspapers or publications? Yes _____ No _____ If so, please list the Arabic language newspapers or publications: _____________________________________________________ (b) If you speak, read, or understand the Arabic language (or any of its 

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

official interpreter’s translation of testimony and witnesses’ translations of Arabic language evidence? Yes _____ No _____

21. Do you speak Swahili (or any dialect of Swahili), or did you grow up in 

households where the Swahili language or any of its dialects were spoken? Yes _____ No _____

(a) Do you read any Swahili language newspapers or publications? Yes _____ No _____ If so, please list the Swahili language newspapers or publications: _____________________________________________________ (b) If you speak, read, or understand the Swahili language (or any of its 

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

official interpreter’s translation of testimony and witnesses’ translations of Swahili language evidence? Yes _____ No _____

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United States v. El-Hage: Juror Questionnaire 7 

22. Are you: ( ) Employed full-time ( ) Retired ( ) Employed part-time ( ) Student ( ) Homemaker ( ) Disabled & unable to work ( ) Unemployed/laid off

(a) Without telling us the name of your employer, what kind of work do 

you do? (For example: electric utility, maintenance; teacher, high 

school.) Please do not write anything that would reveal your identity. _____________________________________________________ (b) If retired or unemployed, what type of work had you been doing? _____________________________________________________ (c) If homemaker or student, please tell us what jobs outside the home 

(if any) you have had in the past: _____________________________________________________ 23. What is (was) your job title? ___________________________________ (a) What are (were) your duties on that job? _____________________________________________________ (b) Do (did) you supervise others in that job? Yes _____ No _____ If yes, how many? _______

24. Do you have a second job? Yes _____ No _____ If yes, what do you do? ___________________________________________________________ 25. How many children do you have, if any? __________________________ 26. If your children are in school, what type of school do they attend? Public _____ Private _____ Religious _____ Home _____

332 332
United States v. El-Hage: Juror Questionnaire 8 

27. List the gender, age, and occupation of each employed child.

Gender Age Occupation

 28. If you have ever been married, list your spouse’s most recent type of work. ___________________________________________________________ 29. Do you have any close friends or relatives who are employed by the United States Department of State or who have worked in an embassy? Yes _____ No _____ If yes, please explain. ___________________________________________________________ 30. Do you: ( ) Own your own home ( ) Rent ( ) Live with relatives or friends

31. What is the highest grade of schooling you have completed? ( ) 8th grade or less ( ) Community college

( ) Some high school ( ) Some four-year college

( ) High school graduate ( ) College graduate ( ) Post graduate

32. Please list all degrees you have received but not the name of the colleges 

you received them from. ___________________________________________________________ 33. Please describe generally what type of civic, educational, professional, 

sports, business, religious, or political activities you participate in. ___________________________________________________________ ___________________________________________________________

___________________________________________________________

___________________________________________________________ 

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United States v. El-Hage: Juror Questionnaire 9 

34. List any organizations to which you belong. Please do not write anything 

that would reveal your identity. (For example, “PTA President,” not “PTA 

President, P.S. 123.”) ___________________________________________________________ ___________________________________________________________

___________________________________________________________ Please tell us your role in the organization. ___________________________________________________________ ___________________________________________________________

___________________________________________________________

___________________________________________________________ 35. What charities or organizations have you contributed to in the last five (5) 

years? ___________________________________________________________ ___________________________________________________________

___________________________________________________________

___________________________________________________________ 36. Do you have any hobbies? Yes _____ No _____ If yes, what are they? ___________________________________________________________ ___________________________________________________________

___________________________________________________________ 37. Do you have any family, relatives, or friends in the military who are currently or were formerly stationed in the Middle East? Yes _____ No _____ If yes, where is, or was, that person? ___________________________________________________________ 38. If you, a family member, or a friend served in the military, was that person 

ever in a combat situation? Yes _____ No _____ Don’t know _____ If yes, please tell us where and when. ___________________________________________________________ 

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United States v. El-Hage: Juror Questionnaire 10

39. How closely did you follow the media coverage of the Gulf War? Very closely _____ Somewhat closely _____ Not too closely _____ Not at all _____

40. (a) How closely did you follow the media coverage of the events in 

Somalia in 1983? Very closely _____ Somewhat closely _____ Not too closely _____ Not at all _____

(b) How closely did you follow the media coverage of Somalia after the 

United Nations and American troops left Somalia?

Very closely _____ Somewhat closely _____ Not too closely _____ Not at all _____

41. (a) How closely have you followed the media coverage of the bombing 

of the U.S.S. Cole in Yemen? Very closely _____ Somewhat closely _____ Not too closely _____ Not at all _____

(b) If you have followed the media coverage of this event, based on 

what you have heard or read, are you of the opinion that the bombing was carried out by any particular group?

Yes _____ No _____ If yes, which group? _____________________________________________________ 42. The government is represented in this case by the United States Attorney, 

Mary Jo White, though the conduct of the case is in the immediate charge 

of the government attorneys appearing in the courtroom. Do you or does 

any relative or friend know or have any connection with Mary Jo White? Yes _____ No _____

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United States v. El-Hage: Juror Questionnaire 11

43. Do you, or does any relative or friend, know or have any connection with 

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

government? Assistant United States Attorney Patrick J. Fitzgerald

Assistant United States Attorney Kenneth M. Karas

Assistant United States Attorney Michael J. Garcia

Assistant United States Attorney Paul W. Butler

Assistant United States Attorney Andrew C. McCarthy

Gerard Francisco (Paralegal Specialist, U.S. Attorney’s Office)

Lillie Grant (Paralegal Specialist, U.S. Attorney’s Office)

Nozomi Maeyama (Records Examiner, U.S. Attorney’s Office) Yes _____ No _____

(a) Have you seen, heard, or read anything about any of these individuals? This includes not only from the media, but anything you may 

have heard from friends, relatives, or co-workers. Yes _____ No _____

(b) What have you seen, heard, or read? _____________________________________________________ _____________________________________________________

_____________________________________________________ 44. Do you or does any relative or friend know or have an connection with any 

of the defendants? Wadih el-Hage Yes ____ No ____

Mohammed Sadeek Odeh Yes ____ No ____

Mohamed al-’Owhali Yes ____ No ____

Khalfan Khamis Mohamed Yes ____ No ____

(a) Have you seen, heard, or read anything about any of the defendants? 

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

heard from friends, relatives, or co-workers. Yes _____ No _____

(b) What have you seen, heard, or read? _____________________________________________________ _____________________________________________________

_____________________________________________________ 

336 336
United States v. El-Hage: Juror Questionnaire 12

45. Several individuals have been charged in the indictment in this case but 

will not be defendants in this trial. Do you, or does any relative or friend, 

know or have any connection with any of these defendants? Usama bin Laden Yes ____ No ____

Muhammed Atef Yes ____ No ____

Ayman al Zawahiri Yes ____ No ____

Khalid al Fawwaz Yes ____ No ____

Ibrahim Eidarous Yes ____ No ____

Adel Abdel Bary Yes ____ No ____

Fazul Abdullah Mohammed Yes ____ No ____

Mustafa Mohamed Fadhil Yes ____ No ____

Ahmed Khalfan Ghailani Yes ____ No ____

Fahid Mohammed Ally Msalam Yes ____ No ____

Mamdouh Mahmud Salim Yes ____ No ____

Sheikh Ahmed Salim Swedan Yes ____ No ____

(a) Have you seen, heard, or read anything about any of these individuals? This includes not only from the media, but anything you may 

have heard from friends, relatives, or co-workers. Yes _____ No _____

(b) What have you seen, heard, or read? _____________________________________________________ _____________________________________________________

_____________________________________________________ 

337
United States v. El-Hage: Juror Questionnaire 13

46. (a) Do you, or does any relative for friend, know or have any connection with any of the following defense lawyers or their staff? Attorneys

Sandra A. Babcock Yes ____ No ____

David P. Baugh Yes ____ No ____

Frederick Cohn Yes ____ No ____

Joshua L. Dratel Yes ____ No ____

Laura K. Gasiorowski Yes ____ No ____

Carl J. Herman Yes ____ No ____

Kristian K. Larsen Yes ____ No ____

Marshall Mintz Yes ____ No ____

Anthony L. Ricco Yes ____ No ____

David Ruhnke Yes ____ No ____

Sam A. Schmidt Yes ____ No ____

Jeremy Schneider Yes ____ No ____

David Stern Yes ____ No ____

Edward D. Wilford Yes ____ No ____ Staff Georgia Alikakos Yes ____ No ____

Diana Barrett Yes ____ No ____

Elizabeth Besobrasow Yes ____ No ____

Robert Hirschorn Yes ____ No ____

Kevin Johnson Yes ____ No ____

Nadia Kahf Yes ____ No ____

Katie Tempone Yes ____ No ____

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

or their staff? This includes not only from the media, but anything 

you may have heard from friends, relatives, or co-workers. Yes _____ No _____

(c) What have you seen, heard, or read? ________________________ _____________________________________________________ _____________________________________________________ 47. The judge who will preside over this case is Judge Leonard B. Sand of the 

United States District Court for the Southern District of New York. Do 

you, or does any relative or friend, know or have any connection with 

Judge Sand or any of his staff? Yes _____ No _____

338 338
United States v. El-Hage: Juror Questionnaire 14

48. Is there any particular news program, magazine, newspaper article, or 

broadcast about this case, the defendants, or the embassy bombings that 

has made a lasting impression on you? Yes _____ No _____ If yes, what was the program, article, or broadcast? ___________________________________________________________ Is there anything you have seen, heard, or read that would interfere with 

your ability to render a fair verdict in this case based solely on the evidence presented in court? Yes _____ No _____

49. Before you came to court today, were you aware that the United States 

embassies in Nairobi, Kenya, and Dar es Salaam, Tanzania, were bombed 

on August 7, 1998? Yes _____ No _____

50. 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 _____

339
United States v. El-Hage: Juror Questionnaire 15

Experience with Courts

51. (a) Have you ever:

(i) sat as a juror in a civil case? Yes _____ No _____

(ii) sat as a grand juror? Yes _____ No _____ (iii) sat as a juror in a criminal case? Yes _____ No _____

(b) Have you ever been a juror in a case where the jury was unable to 

reach a verdict? Yes _____ No _____

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

date(s); (2) whether you served in state court or federal court; 

(3) whether it was a grand jury or a trial jury; (4) whether it was a 

criminal case or a civil case; (5) what the general nature of the case 

was (for example, robbery, murder, contract, negligence, medical 

malpractice, etc.); and (6) whether or not a verdict was reached. If 

so, do not state what the verdict was.

(1)

Date

(2)

State or 

federal

(3)

Grand 

jury or 

trial jury

(4)

Criminal 

or civil

(5)

Nature 

of case

(6)

Was 

there a 

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.

52. Have you ever been questioned in any matter by the United States Department of Justice, the New York City Police Department, or any investigative agency of the United States, including the Federal Bureau of Investigation, the DEA, the IRS, or any other state or federal investigative 

agency? Yes _____ No _____ If yes, please explain the circumstances. ___________________________________________________________ ___________________________________________________________

___________________________________________________________ 

340 340
United States v. El-Hage: Juror Questionnaire 16

53. Have you, or has a family member or close friend, ever been falsely accused of a crime? Yes _____ No _____ If yes, please explain the circumstances. ___________________________________________________________ ___________________________________________________________

___________________________________________________________ 54. Have you, any family member, or friend ever worked for any federal, state, 

or local law enforcement agency? (For example, NYPD, State Police, Sheriff, F.B.I., C.I.A., D.E.A., Probation and Parole, Corrections, U.S. Customs, Secret Service, etc.) Yes _____ No _____ If yes, please tell us who, what agency, how long, and the highest rank 

achieved? ___________________________________________________________ 55. Have you or a relative or friend ever worked or applied for employment 

with a federal, state, or local agency? Yes _____ No _____ If yes, what agency? ___________________________________________________________ 56. 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, 

agents, or employees of the United States? Yes _____ No _____ If yes, please explain the nature of your interest in such proceedings. ___________________________________________________________ ___________________________________________________________

___________________________________________________________ 57. Are you a vendor or a contractor for the United States government, or do 

you work for one? Yes _____ No _____

58. Do you have any difficulty accepting the principle that non-citizens who 

are charged with a crime in a United States court are entitled to the same 

rights as United States citizens? Yes _____ No _____

341
United States v. El-Hage: Juror Questionnaire 17

59. Have you ever attended law school? Yes _____ No _____

60. Do you have any close friends or relatives who are lawyers or who have 

attended law school? Yes _____ No _____

61. Do you, or does any relative or friend, work for a criminal lawyer or private investigator? Yes _____ No _____

62. 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 _____

63. Have you or anyone close to you ever been charged with a crime or been 

the subject of a criminal investigation? Yes _____ No _____

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

legal proceeding? Yes _____ No _____

65. Do you believe that you, a member of your family, or a close friend has 

ever been directly or indirectly affected in any way by a terrorist act or 

threat? Yes _____ No _____

66. The court will instruct you that the testimony of a law enforcement officer 

is entitled to no greater weight or lesser weight than that of any other witness. Do you have any difficulty accepting that statement? Yes _____ No _____

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

informants by federal authorities in their investigations. One or more of 

those individuals may be called to testify in this case and you may learn 

that some of the individuals have participated in serious crimes. The court 

wishes to advise you that there is nothing illegal or improper about the 

government using accomplices or informants to investigate a case. Do you 

have strongly held feelings against the use of informants? Yes _____ No _____

68. Are you or anyone close to you now under subpoena or, to your knowledge, about to be subpoenaed in any criminal case? Yes _____ No _____

342 342
United States v. El-Hage: Juror Questionnaire 18

69. Have you, or has a family member or close friend, ever been the victim of 

a serious crime other than burglary or car theft? Yes _____ No _____

70. There will be evidence in this case consisting of tape recordings of conversations taking place in given locations or over the telephone, through the 

use of electronic devices commonly known as “bugs” or “wiretaps.” Before received in evidence, the court will have ruled that this evidence is 

lawfully before you. Do you have strongly held views against the use of 

secretly tape-recorded conversations or “wiretaps” or “bugs”? Yes _____ No _____

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

including the homes of some of the defendants. Do you have any feelings 

against the use of lawfully conducted surveillance or searches? Yes _____ No _____

72. To your knowledge, have you or any close friend or relative ever been the 

subject of a surveillance (visual, photographic, or electronic) by law enforcement or had a car or home searched by law enforcement officers? Yes _____ No _____

73. The evidence in this case will include pictures of the bodies of the people 

who were killed and injured in the embassy bombings in Kenya and Tanzania in 1998 and testimony of people who suffered those injuries. Is there 

anything about having to view and hear such evidence that would interfere 

with your ability to arrive at a verdict of guilty or not guilty as to any of 

the individual defendants? Yes _____ No _____ If yes, please explain. ___________________________________________________________ ___________________________________________________________

___________________________________________________________ 

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United States v. El-Hage: Juror Questionnaire 19

Religion

74. What, if any, is your current religious affiliation? ___________________________________________________________ 75. What, if any, religion were you raised in? ___________________________________________________________ 76. Have you ever experienced what you believe to be discrimination against 

you because of your religious beliefs? Yes _____ No _____ If yes, please explain. ___________________________________________________________ 77. Do you know anyone who practices the faith of Islam? Yes _____ No _____

78. How knowledgeable are you about the history and practices of Islam? Very knowledgeable _____ Somewhat knowledgeable _____ Not too knowledgeable _____ Not knowledgeable at all _____

79. Is there anything about a case where all the defendants are Muslim that 

would make it hard for you to serve as a juror? Yes _____ No _____

80. Do you have any strong views against the religion of Islam or its adherents? Yes _____ No _____

81. Have you ever traveled outside the United States? Yes _____ No _____ If yes, please explain where and when. ___________________________________________________________ ___________________________________________________________

___________________________________________________________ 

344 344
United States v. El-Hage: Juror Questionnaire 20

82. Some of the defendants in this case are of Arab, Middle Eastern, and African descent.

(a) Are you, or any relatives or close friends, of Arab, Middle Eastern, 

or African descent? Yes _____ No _____

(b) Do you work, or have you worked, with any people of Arab, Middle 

Eastern, or African descent? Yes _____ No _____

(c) Do you socialize with any people of Arab, Middle Eastern, or African descent? Yes _____ No _____

(d) Do you have any negative feelings or opinions about people of 

Arab, Middle Eastern, or African descent? Yes _____ No _____ If yes, please explain. _____________________________________________________ _____________________________________________________

_____________________________________________________ 83. Do you believe that there is a law enforcement bias against people of 

Arabic descent or people of the Islamic faith? Yes _____ No _____ If yes, please explain. ___________________________________________________________ ___________________________________________________________

___________________________________________________________ Potential Punishment

In this case, two of the men on trial—Mohamed al-’Owhali and Khalfan Khamis 

Mohamed—face a potential sentence of death. In a case where individual jurors 

may have to consider death as a possible punishment, it is important that we 

know your thoughts and opinions regarding the death penalty.

If either Mohamed al-’Owhali or Khalfan Khamis Mohamed is found guilty 

of capital crimes, there will be a second phase of the trial—the penalty phase. 

The first phase of the trial deals only with evidence on the question of whether or 

not the government has proved beyond a reasonable doubt the guilt of each of the 

four defendants. During this stage of the trial, the possibility of punishment must 

not enter into your deliberations at all.

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United States v. El-Hage: Juror Questionnaire 21

If the jury determines that either defendant Mohamed al-’Owhali or Khalfan 

Khamis Mohamed is guilty of murder, the jury’s service will not be over. The 

same jury must also decide whether or not the defendant they are considering is 

to be sentenced to death or to life imprisonment without possibility of release. 

That phase of the trial is expected to last three to four weeks.

During the second stage, the government would have the opportunity to introduce evidence as to certain things referred to in the law as aggravating factors, 

or the circumstances that make the crime particularly serious and therefore that 

tend to favor the imposition of the death penalty. Mr. al-’Owhali and Mr. Mohamed would have the opportunity at such a hearing to demonstrate to you the 

existence of what are referred to as mitigating factors, or the circumstances about 

the crime or about the individual defendant that would suggest that the death penalty is not appropriate in this case.

Before the jury could vote to impose the death penalty, it would have to be 

persuaded unanimously and beyond a reasonable doubt that the defendant had the 

requisite state of mind when he engaged in the crime and that at least one of the 

specific aggravating factors identified by the government exists. Moreover, before a jury could vote to impose the death penalty, it would also have to be persuaded unanimously that the aggravating factors it found to exist outweigh any 

mitigating factors that one or more jurors found existed. Even if the jury did not 

find any mitigating factors, it would still have to be persuaded unanimously that 

the aggravating factor or factors were themselves sufficient to justify a death sentence. Absent such unanimous agreement, a jury could not vote to impose the 

death penalty.

In sum, a jury is never required to impose a sentence of death upon a defendant. You should know, however, that if the jury does decide to impose the death 

penalty this court would be required to impose that sentence. Similarly, if you 

decide to impose life imprisonment without parole—an option that would also be 

available to you—the court would be required to impose that sentence. In other 

words, the court could not change your decision.

Obviously, what I have just stated is only an overview of the law applicable 

to a jury’s consideration of the death penalty. If this case were ever to require a 

sentencing hearing—and remember that each of the defendants is presumed innocent of each of the charges that have been brought against him—the court will 

instruct the jury in more detail about its duties.

84. Please circle the number that best reflects your opinion regarding the death 

penalty. Strongly Strongly

Oppose Favor

1 2 3 4 5 6 7 8 9 10 

346 346
United States v. El-Hage: Juror Questionnaire 22

85. How do you feel about the death penalty? _________________________ ___________________________________________________________ ___________________________________________________________

___________________________________________________________ 86. In your opinion, is the death penalty in our society: (Circle all that apply.)

(a) Useful

(b) Necessary

(c) Counterproductive

(d) Inhumane

(e) Other: Please explain. ___________________________________ 87. Please circle the answer or answers that best correspond to your views on 

the death penalty. (You may select more than one.)

(a) The death penalty should be imposed in every case where someone 

deliberately takes the life of another person.

(b) While I favor the death penalty, I do believe that there are rare cases 

where the death penalty should not be imposed even if someone has 

deliberately murdered another person.

(c) While I am somewhat in favor of the death penalty, I do not believe 

it should be used as a punishment for most cases, even where a person has been deliberately murdered.

(d) I have no views one way or the other on the death penalty.

(e) While I am somewhat opposed to the death penalty, I do believe that 

there are many cases where a death sentence should be imposed.

(f) While I am strongly opposed to the death penalty, I do believe there 

are some cases where a death sentence should be imposed.

(g) The death penalty should never be imposed.

88. If the law and the evidence leads to a conclusion that is contrary to your 

present personal beliefs concerning the death penalty, could you set aside 

your own views and act in accord with the court’s instructions? Yes _____ No _____ Not Sure _____ Please explain. ______________________________________________ ___________________________________________________________ ___________________________________________________________

___________________________________________________________ 

347
United States v. El-Hage: Juror Questionnaire 23

89. If the evidence in this case convinces you that the death penalty is appropriate, could you vote to impose the death penalty? Yes _____ No _____ Not Sure _____ Please explain. ______________________________________________ ___________________________________________________________ ___________________________________________________________

___________________________________________________________ 90. Do you believe that the death penalty is sought and imposed unfairly? Sometimes _____ Always _____ Never _____ Please explain. ______________________________________________ ___________________________________________________________ ___________________________________________________________

___________________________________________________________ 91. (a) Have you read or heard anything concerning an attack by defendant 

Khalfan Khamis Mohamed on corrections officers which caused one 

officer serious injury? Yes _____ No _____

(b) If you were to learn that such an attack took place and found that 

Khalfan Khamis Mohamed participated in the attempted murder of a 

corrections officer, would it alter any of your answers to questions 

84 through 90 as to defendant Khalfan Khamis Mohamed? Yes _____ No _____ Uncertain _____

Conclusion—Miscellaneous Information

92. 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 _____

348 348
United States v. El-Hage: Juror Questionnaire 24

93. 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 defendants beyond a reasonable 

doubt? Yes _____ No _____ If yes, please explain. ___________________________________________________________ ___________________________________________________________

___________________________________________________________

___________________________________________________________ 94. Is there any reason that you could not be completely fair and impartial to 

the defendants in this case? Yes _____ No _____

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

the government in this case? Yes _____ No _____ If you answered “yes” to question 94 or question 95, please explain. ___________________________________________________________ ___________________________________________________________

___________________________________________________________

___________________________________________________________ 96. Is there any matter not covered by this questionnaire that you feel you 

should tell us about? Yes _____ No _____ If yes, please explain. ___________________________________________________________ ___________________________________________________________

___________________________________________________________ Juror Number: __________________ Date: _________________________ 

349
United States v. El-Hage: Juror Questionnaire 25

Continuation to any questions (indicate question number): ________________________________________________________________ ________________________________________________________________

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United States v. El-Hage: Juror Questionnaire 26

Continuation to any questions (indicate question number): ________________________________________________________________ ________________________________________________________________

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United States v. El-Hage: Juror Questionnaire 27

Continuation to any questions (indicate question number): ________________________________________________________________ ________________________________________________________________

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352 352
1 

United States v. Abdel Rahman: 

Preliminary Voir Dire 

Hon. Michael B. Mukasey 

Southern District of New York 

January 9, 1995 

The following text was prepared by the Southern District of New York’s United 

States District Judge Michael B. Mukasey to address prospective jurors selected 

for the prosecution of defendants suspected of seditious conspiracy to conduct a 

campaign of urban terrorism, including participation in the 1993 bombing of the 

World Trade Center and plans to bomb New York landmarks, in United States v. 

Abdel Rahman, No. 1:93-cr-181 (S.D.N.Y. Mar. 17, 1993). 

Preliminary Voir Dire 

Good morning, ladies and gentlemen. I am Judge Mukasey, and we are here this 

morning to pick a jury in a criminal case. Our purpose today and in the coming 

days is to pick a jury of citizens who can listen to the evidence in this case and 

decide the case based only on the evidence presented here in court and on my 

instructions as to the law. 

The case is one that many of you—perhaps all of you—have heard about or 

read about. The defendants in this case are charged with participating in a conspiracy, which is simply the legal term for an unlawful agreement, to commit 

various acts of violence, including bombing buildings and other structures, as a 

way of opposing the United States and United States policy in the Middle East, 

and with committing other acts that are said to be related to that conspiracy. 

We are not trying to find people for this jury who have never heard of this 

case or of these charges. We are not even trying to find jurors who have never 

held or expressed an opinion about these charges or about matters related to 

them. We are trying to find jurors who, regardless of what they have seen or 

heard, and even regardless of what they have thought or said, can understand that 

their job as jurors is to decide this case based only on the evidence presented here 

in court, to apply only the legal rules that I explain and no others, and by applying those rules to that evidence to determine whether or not each defendant’s 

guilt has been proved beyond a reasonable doubt. 

We are going to use the following procedure for jury selection: After I finish 

these preliminary remarks, which should take about 20 minutes, each of you will 

be given a questionnaire that contains certain questions for you to answer that 

will help us—the lawyers for the parties and me—to decide whether you can 

serve on this jury. As I will explain in more detail later on, after you finish filling 

out the questionnaire today you will submit it and go home, and then return on 

Wednesday, January 18, at which time some of you will be asked additional 

questions in person. We will use this process to get a panel of about 80 jurors. In 

addition to coming back on January 18, you may be asked to come back once or 

twice more during this selection process. From among this panel of 80 or so, the 

parties will select the 12 jurors and six alternate jurors who will hear and decide 

353
United States v. Abdel Rahman: Preliminary Voir Dire 

2 

the case. I hope, if everything goes smoothly, that we can get started with the trial 

itself not later than Monday, January 30. Of course, if we can start earlier, we 

will. 

The questions in the questionnaire, and those we will ask in person in a few 

days, ask certain facts about you and members of your family: whether you and 

any family members or close friends have any connection with the people or 

events underlying this case; whether you have opinions on certain subjects; and 

other matters, including how you are employed. I hope you understand that this is 

not an attempt to pry into your private life but simply a way of helping all of us 

determine who can serve on this jury. 

Before you are given the questionnaire to fill out, there are a few things I 

should explain about the case. The first is the charges, which are contained in an 

indictment voted by a grand jury. An indictment is simply the document that contains the charges that the government is required to prove beyond a reasonable 

doubt. It is the way that the government brings into court people whom the government claims have violated the law. That is the only function of an indictment 

in a criminal case. An indictment itself is not evidence of the guilt of any defendant. An indictment does not change in any way the presumption of innocence 

that the law gives every accused person at the start of a trial, a presumption that 

stays with the defendant throughout the trial unless and until the jury finds, in 

accordance with legal rules described by the court, that each and every element 

of a charge has been proved beyond a reasonable doubt. 

The indictment in this case contains 28 separate counts or charges, but those 

charges can be described briefly in three categories. The first category of charges 

includes three conspiracy charges; one charge of attempted bombing; two 

charges of soliciting or asking others to commit violent acts; and four charges of 

receiving, using, or carrying weapons or destructive devices. Those charges are 

contained in Counts One through Six and Counts Fifteen through Eighteen of the 

indictment. All of these counts involve charges that some or all of these defendants participated in conspiracies to commit or attempted acts of violence or 

helped others to do so. 

As I mentioned before, a conspiracy is simply an agreement between two or 

more people to violate the law. The first of these conspiracy charges is that all 

defendants named in the indictment agreed to oppose the United States and its 

policies, including its policies in the Middle East, through a series of violent acts, 

including bombings and murder. These acts are said to have included the bombing of the World Trade Center in February 1993 as well as plans to bomb other 

buildings and locations, including FBI headquarters and the Holland and Lincoln 

Tunnels; plans to commit violence against various public figures, including President Hosni Mubarak of Egypt; and plans to try to secure the release of imprisoned members of the group. The indictment charges that these acts were motivated also by opposition to Israel and by a radical interpretation of the Islamic 

religion. The second conspiracy charge is brought against two defendants and 

accuses them of agreeing to help arrange the assassination of Egyptian President 

Hosni Mubarak during a visit he made to the United Nations in the spring of 

1993. The third conspiracy charge is brought against all 12 defendants on trial 

here and accuses them of participating in an unlawful agreement to bomb build354 354
United States v. Abdel Rahman: Preliminary Voir Dire 

3 

ings and other locations. This conspiracy charge differs from the first because 

among other things it does not mention or require proof that opposing United 

States policy was a motive. Count Six of the indictment contains the charge of 

attempted bombing and is brought against 10 of the defendants on trial here. 

Counts Two and Four contain the charges of soliciting or requesting others to 

commit acts of violence, and both of these counts name one defendant. Counts 

Fifteen and Sixteen charge that two defendants received and used a semiautomatic weapon in connection with the bombing conspiracy charged in Count 

Five. Count Seventeen charges seven defendants with using and carrying destructive devices in connection with the bombing conspiracy charged in Count Five, 

and Count Eighteen charges one defendant with using and carrying destructive 

devices in connection with the conspiracy charged in Count One. That is the first 

group or category of charges. 

The second category of charges includes Counts Seven through Fourteen; 

they are brought only against the defendant El Sayyid Nosair, and they all involve conduct that is said to have occurred on November 5, 1990. Count Seven 

charges that on November 5, 1990, he killed a man named Meir Kahane, and 

Count Eight charges that he attempted to kill a man named Irving Franklin. 

Counts Nine and Ten charge that he attempted to kill a U.S. postal inspector 

named Carlos Acosta. Counts Eleven through Fourteen charge that he used and 

possessed a weapon unlawfully on November 5, 1990. 

Finally, the third category of charges—Counts Nineteen through TwentyEight—contain charges only against defendant Ibrahim El-Gabrowny for conduct 

that allegedly occurred on March 4, 1993. Counts Nineteen through Twenty-Two 

charge him with obstruction of justice and assault for allegedly trying to interfere 

with law enforcement officers who were executing a search warrant at his apartment in connection with the investigation of the World Trade Center bombing. 

Counts Twenty-Three through Twenty-Eight charge Mr. El-Gabrowny with possessing forged Nicaraguan passports at the time of his arrest on March 4, 1993. 

As you can see from the description of the charges, this is a case in which 

people are charged with agreeing to commit criminal acts and with committing 

criminal acts. No one here is charged simply with having opinions or expressing 

ideas, neither of which is a crime in this country. 

Each defendant, by entering a plea of not guilty in this case, has denied these 

charges, and the government has the obligation to prove the charges beyond a 

reasonable doubt. 

I have just summarized these charges in a general way not for the purpose of 

describing what is necessary to prove them; I will do that in detail as part of the 

trial. The only purpose of summarizing the charges at this point is so that you can 

understand the reasons for some of the questions you will be asked to answer on 

the questionnaire and later on during the jury selection process. 

When I referred to Count One, I mentioned that the bombing of the World 

Trade Center in February 1993 is charged as part of the conspiracy set out in 

Count One. You may be aware that four men were convicted in this court last 

spring in connection with the World Trade Center bombing. However, those 

convictions have no relevance to this case. Just because those four men were 

convicted does not mean that any of these defendants were involved in that 

355
United States v. Abdel Rahman: Preliminary Voir Dire 

4 

bombing. On the other hand, just because those four men were found to have 

been involved in that bombing does not mean that anyone on trial here, or anyone 

else, could not also have been involved. To put the matter simply, although the 

same bombing is charged as part of this case, the verdict in the other case has 

absolutely nothing to do with this case. 

Now that I have summarized the charges, I will introduce each of the defendants and the lawyers and others who will be participating in the trial of this case. 

The government is represented in this case, as it is in all cases in which the government is a party before this court, by the United States Attorney for the Southern District of New York, Mary Jo White. This case will be presented by Assistant United States Attorneys Patrick Fitzgerald, Robert Khuzami, and Andrew 

McCarthy. Assisting them will be Jane Chu. 

I will now introduce the defendants and their lawyers. You will notice that 

some may be represented by more than one lawyer, and you should draw no conclusion from that fact. The question of whether one or more lawyers represent a 

defendant is simply a matter of convenience and efficiency and should not concern you. The first defendant named in the indictment is Omar Ahmed Ali Abdel 

Rahman who is known also as Sheik Abdel Rahman. 

Dr. Abdel Rahman will be represented by Lynne Stewart, assisted by Ramsey Clark and Abdeen Jabara, and Emanuel Moore also has provided legal counsel to Dr. Abdel Rahman. The second defendant is El Sayyid Nosair. He will be 

represented by Roger Stavis and Andrew Patel. The third defendant is Ibrahim A. 

El-Gabrowny. Mr. El-Gabrowny will be represented by Anthony Ricco and Gary 

Villanueva. Next is Siddig Ibrahim Siddig Ali. He will be represented by Daniel 

Felber of the firm of Balsam and Felber and by Jerry Tritz. The next defendant 

listed in the indictment is Clement Hampton-El, who is represented by Kenneth 

Wasserman. Next is Amir Abdelgani, who is represented by Steven Bernstein. 

The next person listed is Fares Khallafalla. He is represented by Valerie Amsterdam. The next defendant is Tarig Elhassan. He is represented by Joyce London. 

The next defendant listed in the indictment is Fadil Abdelgani, who I should note 

is not the same person as Amir Abdelgani, whom I introduced a moment ago. 

Mr. Fadil Abdelgani is represented by Charles Lavine of the firm of Grossman, 

Lavine, and Rinaldo. The next defendant is Mohammed Saleh, who is 

represented by John Jacobs. The next defendant is Victor Alvarez, who is 

represented by Wesley Serra. And the last defendant listed in the indictment is 

Matarawy Mohammed Said Saleh, who is also called Wahid Saleh and is not the 

same person as Mohammed Saleh, whom I introduced a moment ago. This Mr. 

Saleh—Matarawy Saleh or Wahid Saleh—is represented by Thomas Nooter of 

the firm of Freeman, Nooter, and Ginsberg. 

Obviously, when you hear a lot of names and see a lot of faces it is difficult 

at first to keep everyone straight, particularly when some people have similar 

names. But I can assure you that as the trial progresses you will have no difficulty keeping everyone’s identity straight, and there are name cards on the table in 

front of each person identifying that person. 

Now that I have introduced the parties and their lawyers, I should tell you a 

couple of additional facts about the case that may help you fill out the questionnaire and help you understand how the privacy of jurors can and will be pre356 356
United States v. Abdel Rahman: Preliminary Voir Dire 

5 

served in a case like this in which there has been a good deal of public interest. 

Some of you may have heard or read about jurors being sequestered. The jury in 

this case will not be sequestered. The jurors will go home every night. However, 

the names and addresses and other identifying information about jurors, such as 

their places of employment, will not be disclosed to anyone other than the jury 

clerk who will send each juror his or her check for jury service. That is to ensure 

that the privacy of jurors is preserved and that you are not contacted by the press 

or by others who may be curious to discuss the case. In addition, jurors will be 

picked up each morning by deputy U.S. Marshals at a convenient meeting place, 

or perhaps at several different places, and driven to the courthouse. While the 

jury is in the courthouse, its members will remain with the marshals and will take 

their coffee breaks and meals together. A light breakfast—coffee and other refreshments—and lunch will be provided by the court during the day for the jurors. In the evening, the jurors will be driven from the courthouse by the marshals 

back to a convenient drop-off point, or perhaps several drop-off points, and will 

make their way home. The jury will hear evidence in the case four days a week—

Monday through Thursday—at least initially. I hope it will not be necessary for 

us to go to a five-day-a-week schedule, but I cannot promise that. 

Perhaps I should say a few words about the security procedures in this case. 

When you came to the courthouse this morning you may have noticed that there 

are marshals and other security people posted inside and outside. The security 

people are here simply to ensure that whatever people’s opinions or feelings may 

be about this case, they will not cause disruption of the trial, and that the jury can 

proceed in an orderly way to hear the evidence and decide the case based only on 

the evidence and on my instructions as to the law. 

I am sure you are wondering how long the trial will take. Actually, I am 

wondering the same thing. It is not possible to predict with great accuracy how 

long it will take, but the best estimate I can make—and it is only an estimate—is 

that it will take between six and nine months. I know that is a very long time, and 

there may be many of you who simply cannot take that amount of time to hear a 

case, even four days a week. I will discuss that later. But please understand that 

the lawyers and the court will do everything we can to present the case as quickly 

as possible, consistent with giving everyone here—both the defendants and the 

government—a fair trial. I should also tell you that after 30 days of trial, the jury 

fee you receive goes from $40 per day to $50 per day, so there is some slight additional compensation in a longer trial such as this. In addition, jurors will be 

paid for the cost of public transportation to and from whatever pick-up and dropoff point the marshals use. 

You should also know that no one who is employed need be concerned about 

how their employer might react to their service on a jury during a lengthy trial. 

Most employers, I think, are pretty good and understanding about that, but in any 

event there is a federal statute that forbids any discrimination of any kind against 

anyone on account of jury service. I have made sure in the past that that statute 

was scrupulously observed by the employers of jurors who have served in this 

court, and you have my word that I will do so in this case. So you will not lose 

seniority or any other employment right as a result of your jury service. Although 

that statute does not require that an employer pay a person his or her salary dur357
United States v. Abdel Rahman: Preliminary Voir Dire 

6 

ing jury service, it does require that any employer who has a policy of paying 

employees during jury service continue to apply that policy. 

During the trial, those who serve on the jury will have to agree not to read 

any of the newspaper or magazine reports about the case or watch or listen to any 

radio or television news report about the case. I may discuss the reasons for that 

in greater detail later during or after jury selection, but you can probably figure 

out the reasons for that yourselves. Those who are selected to serve on the jury 

will take an oath to decide the case based only on the evidence presented in court. 

There are two parts to that. First, it is the jurors who must decide the case for 

themselves; and second, they must do so based only on evidence received in 

court. If jurors read and are influenced by news reports about the case, in effect 

they are surrendering their responsibility to news reporters or to people whose 

comments the reporters quote in the newspapers or on radio or television. Reporters frequently highlight what is interesting and easy to understand. As you 

probably realize, not everything that is interesting and easy is necessarily important, and not everything that is important is necessarily interesting or easy. Even 

when reporters try in good faith to get facts correct, they are often working in a 

hurry with partial information, and they do not have an unlimited amount of 

space or time to explain the facts. To put it simply, even when media representatives try their best, they may not get it right or complete. 

Also, people may be quoted in news reports who have an interest in having 

the case come out one way or the other, and those people will say things they 

hope will influence public opinion one way or the other. There have already been 

several people quoted in news reports about this case who fit that description, 

some of them currently involved in this case, some not. People with an interest in 

having the case come out one way or the other naturally will say what they think 

helps the side they want to help, and they will avoid discussing anything they 

think does not help their side. There have already been many statements like that 

reported about this case in the newspapers, on television, and elsewhere. Needless to say, such statements are not evidence, and many such statements have included outright falsehoods about what the evidence will show. If a juror is influenced by statements in press reports, which are not evidence and which the parties to this case do not have a chance to rebut or explain, then that juror is not 

being true to his or her oath to decide the case for himself or herself and to decide 

it based on the evidence and not based on news reports. That is just a summary of 

the reasons why we do not want jurors being influenced by news reports, and the 

easiest way not to be influenced by news reports is not to see or hear them. Start 

today. 

I will also ask you today and on future days not to talk to anyone about this 

case, particularly not to reporters if they try to question you about it. Obviously, I 

am also asking the reporters not to try to question jurors or potential jurors because that could simply disqualify those jurors from service and would be interfering with the process of selecting a jury in this case. 

But although you will not be able to read about this case or hear about it from 

news reports, you should know that we will make available to the jurors at the 

courthouse the local daily newspapers with the stories about this case deleted, so 

you will be able to keep up with sports—at least those sports that are still being 

358 358
United States v. Abdel Rahman: Preliminary Voir Dire 

7 

played—and with other important things like the comics. Unfortunately, none of 

us will be able to keep up with the Far Side cartoons because Gary Larson has 

decided to retire and stop drawing them, but we will be able to keep up with everything else. 

I am almost done with these preliminary remarks, and I thank you for your 

attention. A moment ago, when I mentioned the projected length of the trial, 

some of you looked and even sounded uncomfortable. Others may feel that they 

would have difficulty serving because of the nature of the charges. I want to assure you that no one is going to be forced to serve on this jury who should not sit 

because he or she really cannot decide the case based only on the evidence but 

rather would be influenced by other considerations, or who cannot sit because 

that person simply cannot afford the time away from business or other pressing 

matters. That is part of what we will be trying to find out through the questionnaire. But I hope when you answer the questions on that questionnaire you will 

keep the following in mind: If you, or someone close to you, were accused of a 

crime, or were the victim of a crime, or were simply involved in an accident or 

some other event that caused a lawsuit, you would expect a group of your fellow 

citizens to put aside their beliefs and prejudices, and their other activities, for 

whatever time it took to hear your case; and you would have every reason to expect that because it is your right in this country to expect it. The people involved 

in this case have a right to expect that as well. Also, each of you took an oath 

before we started that you would give truthful answers to all questions put to you 

touching upon your qualifications to serve as jurors. Everything that happens in 

this building depends on people taking oaths seriously. No witness is allowed to 

testify until the witness takes an oath. Each of these lawyers took an oath before 

that lawyer was permitted to practice in this court. I had to take an oath before I 

assumed my responsibilities here. Your oath is no less important than the oaths of 

others who participate in this trial, and it applies to the questions on the questionnaire. 

Just a few more words about the questionnaire and then I am finished. The 

form is about 20 pages long. Most of the questions are “Yes/No” questions, so 

you will not have to sit and write any long answers. There are two sets of questions on the questionnaire—questions 20(a) and (b) and questions 76 through 

80—that I should mention in particular. Questions 20(a) and (b) ask about the 

ethnic background of you and your spouse, and questions 76 through 80 ask 

about your religious background. Those questions are optional. You need not 

answer them if you would prefer not to do so. Whether you answer them or not, 

please understand that we do not pick juries in this country, and we will not pick 

this jury, based on ethnic background or religion. The only reason those questions are there is that a person’s background, whether ethnic or religious, might 

possibly help someone reading the questionnaire better understand the answers to 

other questions. But again, you need not answer such questions if you would prefer not to do so, and the questionnaire says just that before each of those questions. 

Finally, as I mentioned, no one but the jury clerk will know the identity of 

the jurors. Each of you has been given a juror number. That number should go on 

the form in the designated space. Please do not put your name anywhere on the 

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United States v. Abdel Rahman: Preliminary Voir Dire 

8 

form. The only person who has a list of the names corresponding to the numbers 

you have is the jury clerk who will issue the checks to the jurors for their jury 

service, so the lawyers and others who get copies of the questionnaire to review 

will not know the name or other identifying information about jurors. 

After you have finished filling out the questionnaire, you may give it to the 

clerk, who will make sure that it is complete and that your number appears in the 

proper place. You may then go home. We will ask you to return on _______ at 

1:00 p.m. to Courtroom 110, where you are about to go to fill out your questionnaires and which is just across the hall from the jury assembly room, and you will 

be told then whether you will be asked any further questions as part of the remainder of the jury selection process. Those who are to be questioned further will 

meet with me and the lawyers and the defendants in a conference room, one by 

one, and we will have whatever further discussion we need to have. After that, 

we will pick about 45 jurors at random, and they may be asked some additional 

questions in open court. From this group, we will select the 18 jurors who will 

hear and decide this case. 

I will now ask each of you to go with the marshals to the room where you 

will fill out your questionnaire. When you are done, just signal to one of the 

clerks that you have finished the form, and one of them will come by and review 

the form to make sure it is complete. You are then free to leave. 

Once again, thank you for your attention. Have a pleasant day and a safe trip 

home. 

360 360
 

1 

United States v. Abdel Rahman:

Jury Questionnaire

Hon. Michael B. Mukasey

Southern District of New York

January 9, 1995

The following questionnaire was prepared by the Southern District of New 

York’s United States District Judge Michael B. Mukasey to facilitate jury selection in the prosecution of defendants suspected of seditious conspiracy to conduct 

a campaign of urban terrorism, including participation in the 1993 bombing of 

the World Trade Center and plans to bomb New York landmarks, in United 

States v. Abdel Rahman, No. 1:93-cr-181 (S.D.N.Y. Mar. 17, 1993).

Introduction

The furnishing of information on this questionnaire is designed to expedite the 

jury selection process in this case. If you have any inquiries concerning any particular question, please contact the court and it will be explained to you.

The jurors are advised that the Court is aware that some of the questions contained in the questionnaire are of a personal nature. Nonetheless, the Court must 

ensure that the jury that hears this case can be completely fair to both sides and 

that both sides have sufficient information about each juror’s background and 

experiences that they can feel comfortable that a fair and impartial jury will hear 

this case.

Please be completely frank and candid in responding to this questionnaire. 

Please do not discuss the questionnaire or your answers with anyone. It is very 

important that the answers be yours and yours alone. Remember that there are no 

“right” or “wrong” answers—only truthful answers. You are sworn to give true 

and complete answers to all questions.

Your answers will not become public and, indeed, the Court and the parties 

will not even know your name. Selecting an anonymous jury is not an unusual 

practice and has been followed in many cases in Federal Court. Anonymity will 

ward off curiosity that might infringe on a juror’s privacy. Please write only your 

juror number, and not your name, on this page.

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United States v. Abdel Rahman: Jury Questionnaire

2 

Questions

1. The Court and the parties estimate that after a jury is selected this case will 

last approximately 6 to 9 months. It is anticipated that the jury in this case 

will be sitting four (4) days per week, not including holidays. If, however, 

it becomes necessary, we may have to sit five (5) days per week. Jury service is one of the highest duties and privileges of a citizen. Mere inconvenience or the usual financial hardships of jury service will be insufficient 

to excuse a prospective juror. Do you wish to apply to the Court to be excused on the ground that jury service would be a serious hardship? Yes _____ No _____ If yes, briefly explain the hardship. [Note: If the hardship claimed is financial, please do not name your employer but merely describe in general terms the nature of the situation.] ___________________________________________________________ ___________________________________________________________

___________________________________________________________

___________________________________________________________ 2. (a) Do you have any problem with your hearing or vision that would 

make it difficult for you to serve as a juror? Yes _____ No _____

(b) Do you have any medical condition that would make it difficult for 

you to serve as a juror on this case? Yes _____ No _____

(c) Are you taking any medication that may interfere with your ability 

to concentrate? Yes _____ No _____

(d) Do you have any difficulty in reading or understanding English? Yes _____ No _____ If you answered “yes” to any of these questions, please explain the circumstances. ___________________________________________________________ ___________________________________________________________ 3. The Government is represented in this case by the United States Attorney, 

Mary Jo White, though the conduct of the case is in the immediate charge 

of the Government attorneys appearing in the courtroom. Do you or does 

any relative or friend know or have any connection with Mary Jo White? Yes _____ No _____

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United States v. Abdel Rahman: Jury Questionnaire

3 

4. Do you or does any relative or friend know or have any connection with 

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

Government? Assistant United States Attorney Andrew C. McCarthy

Assistant United States Attorney Robert S. Khuzami

Assistant United States Attorney Patrick J. Fitzgerald

Special Agent Chris Voss (FBI)

Special Agent John Liguori (FBI)

Detective Thomas Corrigan (NYPD)

Jane Chu (Legal Assistant, U.S. Attorney’s Office) Yes _____ No _____

(a) Have you seen, heard, or read anything about any of these individuals? This includes not only from the media, but anything you may 

have heard from friends, relatives, or co-workers. Yes _____ No _____

(b) What have you seen, heard, or read? ________________________ _____________________________________________________ _____________________________________________________

_____________________________________________________

_____________________________________________________ 5. (a) Do you or does any relative or friend know or have any connection 

with any of the defendants? Omar Ahmad Ali Abdel Rahman Yes ____ No ____

El Sayyid Nosair Yes ____ No ____

Ibrahim El-Gabrowny Yes ____ No ____

Siddig Ibrahim Siddig Ali Yes ____ No ____

Clement Hampton-El Yes ____ No ____

Amir Abdelgani Yes ____ No ____

Fares Khallafalla Yes ____ No ____

Tarig Elhassan Yes ____ No ____

Fadil Abdelgani Yes ____ No ____

Mohammed Saleh Yes ____ No ____

Victor Alvarez Yes ____ No ____

Matarawy Saleh Yes ____ No ____

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United States v. Abdel Rahman: Jury Questionnaire

4 

(b) Have you seen, heard, or read anything about this case or any of the 

defendants? This includes not only from the media, but anything 

you may have heard from friends, relatives, or co-workers. Yes _____ No _____

(c) What have you seen, heard, or read? ________________________ _____________________________________________________ _____________________________________________________ 6. (a) Do you or does any relative or friend know or have any connection 

with any of the following defense lawyers? Emanuel Moore (legal advisor to Omar Abdel Rahman)

Roger Stavis

Andrew Patel

Anthony Ricco

Gary Villanueva

Daniel Felber

Gerald Tritz

Kenneth Wasserman

Steven Bernstein

Valerie Amsterdam

Joyce London

Charles Lavine

John Jacobs

Wesley Serra

Thomas Nooter Yes _____ No _____

(b) Have you seen, heard, or read anything about any of these attorneys? This includes not only from the media, but anything you may 

have heard from friends, relatives, or co-workers. Yes _____ No _____

(c) What have you seen, heard, or read? ________________________ _____________________________________________________ _____________________________________________________

_____________________________________________________ 

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United States v. Abdel Rahman: Jury Questionnaire

5 

7. (a) Have you seen, heard, or read anything about any of the following 

attorneys, whose names may be mentioned during the trial? This includes not only from the media, but anything you may have heard 

from friends, relatives, or co-workers. Harry Batchelder

Michael Warren

William Kunstler

Ronald Kuby

Howard Leader

Lawrence Schoenbach

Frank Handelman

Alan Nelson

David L. Lewis Yes _____ No _____

(b) What have you seen, heard, or read? ________________________ _____________________________________________________ _____________________________________________________

_____________________________________________________ 8. Have you seen, heard, or read anything about this case? Yes _____ No _____ What was the source of the information (radio, TV, newspaper, etc.)? ___________________________________________________________ 9. If you have seen, heard, or read something about this case, the defendants, 

or the attorneys, is there anything about what you have seen, heard, or read 

that would prevent you from rendering a fair and impartial verdict based 

solely on the evidence presented in court? Yes _____ No _____

10. Are you aware that the World Trade Center was bombed? Yes _____ No _____

11. (a) Were you or any close friend or relative at or near the World Trade 

Center when it was bombed? Yes _____ No _____

(b) Have you or anyone close to you avoided entering the World Trade 

Center since that time? Yes _____ No _____

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United States v. Abdel Rahman: Jury Questionnaire

6 

(c) Do you or does any close friend or relative regularly use the Holland Tunnel, Lincoln Tunnel, or George Washington Bridge? Yes _____ No _____

(d) Have you or has anyone close to you avoided using the Holland 

Tunnel, Lincoln Tunnel, or George Washington Bridge as a result of 

this case? Yes _____ No _____

(e) Is there anything about a case involving charges concerning the 

bombing of the World Trade Center or plans to bomb the United 

Nations, the Holland Tunnel, the Lincoln Tunnel, and the George 

Washington Bridge that would make it difficult for you to serve as a 

juror in this case? Yes _____ No _____

(f) If you answered any of the questions (a) through (e) “yes,” please 

explain. _____________________________________________________ _____________________________________________________ 12. Have you seen, heard, or read anything about the “World Trade Center” 

case? Yes _____ No _____

13. Have you ever heard of Rabbi Meir Kahane? Yes _____ No _____ If yes, what have you heard? ___________________________________________________________ 14. You will learn that there was a prior state trial concerning Rabbi Kahane 

and defendant El Sayyid Nosair. Have you ever heard about it? Yes _____ No _____ If yes, what have you heard? ___________________________________________________________ ___________________________________________________________ 

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United States v. Abdel Rahman: Jury Questionnaire

7 

15. Some of the witnesses to be called at this trial testified at the earlier trial. 

You are not to speculate as to the reasons why a separate federal trial is being brought. The Court instructs you that this trial is proper and specifically does not violate double jeopardy. Does this cause you any concern? Yes _____ No _____ If yes, please explain. ___________________________________________________________ ___________________________________________________________ Would you have any difficulty accepting my instruction that the outcome 

of the first trial and the reasons for the second trial are irrelevant to this 

proceeding? Yes _____ No _____

16. This case may receive 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 and 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 _____

Personal Background

17. (a) What is your age? _____________

(b) Are you: Male _____ Female _____

18. What is your place of birth? (Please list only the city and state and, if outside the United States, the country.) ___________________________________________________________ 19. Are you (check one): Married _____________ Single _____________ Divorced/Separated _____________ Widow/Widower _____________

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United States v. Abdel Rahman: Jury Questionnaire

8 

20. (a) What is your ethnic background? _____________________________________________________ (b) If married, what is the ethnic background of your spouse? _____________________________________________________ 21. (a) What is your county of residence? _____________________________________________________ (b) In what states or counties have you lived in the past 10 years? _____________________________________________________ 22. Do you read a newspaper regularly (at least two or three times a week)? Yes _____ No _____ If yes, list the names of the newspapers you read and indicate how often 

you read each newspaper.

Name of 

Newspaper

Once a 

week

2–3 

times a 

week

More 

than 4x 

a week Daily

Sunday 

only

 23. What magazines or periodicals do you read? ___________________________________________________________ ___________________________________________________________ 24. Do you watch any television newscasts on a regular basis? Yes _____ No _____ If yes, which ones? ___________________________________________________________ ___________________________________________________________ 25. Do you watch TV shows like “Hard Copy,” “Current Affair,” or “Inside 

Edition”? Yes _____ No _____

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United States v. Abdel Rahman: Jury Questionnaire

9 

26. Do you watch police or crime shows such as “America’s Most Wanted,” 

“Cops,” or “Unsolved Mysteries”? Yes _____ No _____

27. Do you listen to any radio stations on a regular basis? Yes _____ No _____ If yes, which ones? ___________________________________________________________ ___________________________________________________________ 28. (a) Do you speak Arabic (or any dialect of Arabic), or did you grow up 

in households where the Arabic language or any of its dialects was 

spoken? Yes _____ No _____

(b) Do you read any Arabic language newspapers or publications? Yes _____ No _____ If so, please list the Arabic language newspapers or publications. _____________________________________________________ _____________________________________________________ (c) If you speak, read, or understand the Arabic language (or any of its 

dialects), would you have any difficulty relying upon the official interpreter’s translation of testimony and witnesses’ translations of 

Arabic language evidence? Yes _____ No _____

(d) What other languages, if any, do you speak or understand? _____________________________________________________ Employment

Note: Please do not indicate the names of employers in answering any of the following questions. Please refer to employment matters generically, e.g., “bank 

teller.”

29. Are you: ( ) Employed full-time ( ) Retired ( ) Employed part-time ( ) Student ( ) Homemaker ( ) Disabled ( ) Unemployed/laid off

(a) If employed full- or part-time, what type of work do you do for a 

living? _____________________________________________________ _____________________________________________________ 

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United States v. Abdel Rahman: Jury Questionnaire

10

(b) If retired or unemployed, what type of work had you been doing? _____________________________________________________ _____________________________________________________ (c) If a homemaker or a student, have you a job skill which you have 

worked at? Yes _____ No _____ If yes, what? _____________________________________________________ 30. What is (was) your job title? ___________________________________ (a) What are (were) your duties on that job? _____________________________________________________ _____________________________________________________ (b) Do (did) you supervise others in that job? Yes _____ No _____ If yes, how many? ______________________________________ 31. Do you have a second job? Yes _____ No _____ If yes, what do you do? ___________________________________________________________ 32. How many children do you have, if any? __________________________ 33. List the sex, age, and occupation of each employed child.

Sex Age Occupation

 

34. If you have ever been married, list your spouse’s most recent type of 

work? ___________________________________________________________ ___________________________________________________________ 35. Do you: ( ) Own your own home ( ) Rent ( ) Live with relatives or friends

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United States v. Abdel Rahman: Jury Questionnaire

11

36. What is the highest grade of schooling you have completed? ( ) 8th grade or less ( ) Community college

( ) Some high school ( ) Some four-year college

( ) High school graduate ( ) College graduate ( ) Post graduate If you have training or education beyond high school, please list the 

field(s) of study. ___________________________________________________________ Please list all degrees you have received but not the names of the colleges 

you received them from. ___________________________________________________________ ___________________________________________________________ 37. Please describe generally what type of civic, educational, professional, 

sports, business, religious, or political activities you participate in? [Note:

Please do not name the organization but indicate your role in the activity 

or organization; i.e., “active,” “inactive,” or “leader.”] ___________________________________________________________ ___________________________________________________________ 38. What charities or organizations have you contributed to in the last five (5) 

years? (The answer to this question is optional.) ___________________________________________________________ ___________________________________________________________ 39. Do you have any hobbies? Yes _____ No _____ If yes, what are they? _________________________________________ ___________________________________________________________ 

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United States v. Abdel Rahman: Jury Questionnaire

12

40. Have you ever served in the military? Yes _____ No _____ Has your spouse served in the military? Yes _____ No _____

If yes to either, complete the following, and indicate whether this concerns 

you or your spouse. Branch ___________________________ from 19___ to 19___ [Note: Describe only the branch: “Army,” “Navy,” etc.] Rank ___________________________ Were you or your spouse in combat? Yes _____ No _____

41. Have you or a spouse had any experience in military intelligence? Yes _____ No _____ If yes, please explain. _________________________________________ ___________________________________________________________ 42. Were you ever a member of the military police or shore patrol? Yes _____ No _____ If yes, please explain. _________________________________________ ___________________________________________________________ 43. Were you or anyone close to you ever involved in a court martial? Yes _____ No _____ If yes, please explain. _________________________________________ ___________________________________________________________ 44. Have you or has any member of your family or friends ever attended any 

para-military training or a survival school, class, or training seminar, or 

participated in war games? Yes _____ No _____ If yes, please explain. _________________________________________ ___________________________________________________________ 45. Do you or does anyone in your house own any firearms? Yes _____ No _____ If yes, what type and for what purpose? ___________________________ ___________________________________________________________ 

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United States v. Abdel Rahman: Jury Questionnaire

13

46. Do you belong to any organization that takes positions on gun control (either for or against), such as the National Rifle Association? Yes _____ No _____ If so, please list the organizations or associations you belong to. ___________________________________________________________ Experience with Courts

47. (a) Have you ever sat:

(i) as a juror in a civil case? Yes _____ No _____

(ii) as a grand juror? Yes _____ No _____ (iii) as a juror in a criminal case? Yes _____ No _____

(b) Have you ever been a juror in a case in which the jury was unable to 

reach a verdict? Yes _____ No _____

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

date(s); (2) whether you served in state court or federal court; (3) 

whether it was a grand jury or a trial jury; (4) whether it was a criminal case or a civil case; (5) what the general nature of the case was 

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

do not state what the verdict was.

Date

State or 

federal

Grand 

jury or 

trail jury

Criminal 

or civil

Nature of 

case

Was there 

a verdict?

 

48. Do you have any concerns about serving on an anonymous jury? Yes _____ No _____ If yes, please explain. _________________________________________ ___________________________________________________________ 

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49. Have you ever sued anyone or been sued by anyone? Yes _____ No _____

50. Have you, or has anyone you know well, ever been employed or received 

training in any local, state, or federal law enforcement agency, including 

but not limited to the following. (Circle as many as apply for each category.) Close Close Self Relative Friend

FBI x x x 

CIA x x x 

U.S. Attorney x x x 

Internal Revenue Service x x x 

Immigration/Naturalization Service x x x 

Drug Enforcement Agency x x x 

Alcohol, Tobacco, and Firearms x x x 

Military Police x x x 

Prison Guards x x x 

State Troopers x x x 

Police Department x x x 

District Attorney x x x 

U.S. Marshal x x x 

U.S. Treasury Department x x x 

Joint Terrorist Task Force x x x 

Port Authority of New York & New Jersey x x x 

51. Have you or has a relative or friend ever applied to a federal, state, or local 

agency for employment? Yes _____ No _____

52. Have you ever attended law school? Yes _____ No _____

53. Do you have any close friends or relatives who are lawyers or who have 

attended law school? Yes _____ No _____

54. Do you or does any relative or friend work for a criminal lawyer or private 

investigator? Yes _____ No _____

55. Are you or do you have any close relative or friend who is a judge, law 

clerk, court attendant, court clerk, other type of court personnel, probation 

officer, or person connected with any penal institution, jail, or penitentiary? Yes _____ No _____

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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 

each juror (or a juror’s 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 this case. Please do not feel 

embarrassed about any questions, as the answers will be treated in strict confidence.

56. Have you or has anyone close to you ever been charged with a crime or 

been the subject of a criminal investigation? Yes _____ No _____

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

legal proceeding? Yes _____ No _____

58. Are you or is anyone close to you now under subpoena or, to your knowledge, about to be subpoenaed in any criminal case? Yes _____ No _____

59. Have you ever visited a jail or prison? Yes _____ No _____

60. 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), Internal 

Revenue Service (IRS), Immigration and Naturalization Service (INS), or 

Customs Service? Yes _____ No _____

61. Have you ever been involved, or do you expect to become involved, in any 

legal action or dispute with the United States or any agency, officer, or 

employee of the United States, or have you ever had any financial interest 

in such a dispute? Yes _____ No _____

62. Have you or has a family member or close friend ever been the victim of a 

crime? Yes _____ No _____

63. Have you or has a family member or close friend ever been falsely accused 

of anything? 

Yes _____ No _____

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64. Have you ever been treated for a substance abuse problem (for example, 

alcohol or illegal or prescription drugs)? Yes _____ No _____

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

officer or federal agent, who testifies in court is (circle one):

a more likely to tell the truth than other witnesses

b about as likely to tell the truth as other witnesses

c less likely to tell the truth than other witnesses

66. You may hear testimony in this case concerning the use of informants by 

federal authorities in their investigations. One or more of those individuals 

may be called to testify in this case, and you may learn that some of the 

individuals have participated in serious crimes. Others may be expecting to

receive a very substantial reward, as will be brought out in the evidence at 

trial. The Court wishes to advise you that there is nothing illegal or improper about the Government using informants to investigate a case. Do you 

have strongly held feelings about informants? Yes _____ No _____ If you have such views, please describe them. ___________________________________________________________ ___________________________________________________________

___________________________________________________________ 67. The Government expects to call Emad Salem as one of the Government 

witnesses in this case. You will learn that Emad Salem, a former Egyptian 

military person, was a Government informant in this case. Have you seen, 

heard, or read anything about Emad Salem? Yes _____ No _____ If so, what have you heard or read? ___________________________________________________________ ___________________________________________________________ 

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68. There may be evidence in this case about the activities of American or foreign intelligence agencies. Do you have any strong feelings about American intelligence services, foreign intelligence services in general, or the 

Egyptian government and its intelligence services in particular? Yes _____ No _____ If you have such views, please describe them. ___________________________________________________________ ___________________________________________________________

___________________________________________________________ 69. There will be evidence in this case consisting of tape recordings made by 

an informant of one or more of the defendants at a time when the defendants did not know they were being recorded. In addition, there will be 

evidence in this case in the form of tape recordings of conversations taking 

place in given locations or over the telephone through the use of electronic 

devices commonly known as “bugs” or “wiretaps.” Do you have strongly 

held views about secretly tape recording conversations or “wiretaps” or 

“bugs”? Yes _____ No _____ If you have such views, please describe them. ___________________________________________________________ ___________________________________________________________

___________________________________________________________

___________________________________________________________ 70. There may also be evidence obtained from photographic and physical surveillance as well as evidence seized pursuant to searches of various places, 

including the homes of some of the defendants. Do you have any feelings 

about the use of lawfully conducted surveillance or searches? Yes _____ No _____ If you have such views, please describe them. ___________________________________________________________ ___________________________________________________________

___________________________________________________________

___________________________________________________________ 

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71. To your knowledge, have you or has any close friend or relative ever been 

the subject of surveillance (visual, photographic, or electronic) by law enforcement or ever had a car or home searched by law enforcement officers? Yes _____ No _____

72. Defendant Omar Abdel Rahman has chosen to proceed at this trial as his 

own attorney. Emanuel Moore is an attorney who will serve as Omar Abdel Rahman’s legal advisor. Mr. Moore is not acting as Omar Abdel Rahman’s attorney and Abdel Rahman shall direct his own defense. Each juror 

should judge whatever arguments, if any, Omar Abdel Rahman chooses to 

make on the merits of the arguments, just as that juror will judge the merits 

of the arguments made by any other defense counsel. In other words, no 

juror is to accord any less weight to Omar Abdel Rahman’s arguments because he does not have formal legal training. On the other hand, no juror is 

to treat Omar Abdel Rahman’s arguments by any easier standard because 

he does not have formal legal training. Would you have any difficulty following this rule? Yes _____ No _____

73. The statements and arguments of counsel are not evidence. Similarly, the 

questions of counsel are not evidence. Only sworn testimony subject to 

cross-examination is considered testimony at trial. Since Omar Abdel 

Rahman is representing himself, you will be instructed that you must not 

consider Omar Abdel Rahman’s arguments and questions to you as testimony. Would you have any difficulty following this rule? Yes _____ No _____

74. Is there anything about the fact that Omar Abdel Rahman has chosen to 

represent himself that causes you any difficulty? If so, please explain. ___________________________________________________________ ___________________________________________________________ 75. Does the fact that defendant Omar Abdel Rahman is blind make it difficult 

for you to follow the proposition of law that sympathy will not enter into 

the deliberations of the jury? Yes _____ No _____

Note: Questions 76 through 80 concerning religion are optional.

76. What, if any, is your current religious affiliation? ___________________ ___________________________________________________________ 77. What, if any, religion were you raised in? _________________________ ___________________________________________________________ 

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78. Would you consider yourself to be: _____ Very religious

_____ Somewhat religious

_____ Not too religious

_____ Not religious at all

79. (a) Have you ever experienced what you believe to be discrimination 

against you because of your religious beliefs? Yes _____ No _____

(b) Have you ever experienced violence against you because of your religious beliefs? Yes _____ No _____ If yes to either question, please explain. ___________________________________________________________ ___________________________________________________________ 80. Do you or does any close friend or family member practice Islam? Yes _____ No _____

81. The defendants are members of the Islamic faith. Do you know anything about or have any opinion about the teachings or 

doctrines of Islam? Yes _____ No _____ If yes, please explain. _________________________________________ ___________________________________________________________ 82. Have you ever heard the word “Jihad”? Yes _____ No _____ If yes, what does it mean to you? ___________________________________________________________ ___________________________________________________________ 83. (a) Have you ever been to the Abu Bakr Mosque (“Masjid Abu Bakr”), 

the Al-Taqwa Mosque (“Masjid al-Taqwa”), or the Al-Farooq Mosque (“Masjid al-Farooq”) in Brooklyn? Yes _____ No _____

(b) Have you ever been to the Al Salaam Mosque (“Masjid al-Salaam”) 

in Jersey City, New Jersey? Yes _____ No _____

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(c) Have you ever been to the Atlantic Avenue section of Brooklyn between Fourth Avenue and Court Street? Yes _____ No _____

(d) Have you ever attended a speech, sermon, or lecture by defendant 

Omar Abdel Rahman? Yes _____ No _____

(e) Have you ever seen or heard a recorded speech, sermon, or lecture 

by defendant Omar Abdel Rahman? Yes _____ No _____

84. (a) Is there anything about a case in which all of the defendants are 

Muslims (which means they practice Islam) that would make it hard 

for you to serve as a juror? Yes _____ No _____

(b) One defendant is an African-American Muslim. Would that fact 

cause you to judge his case any differently? Yes _____ No _____

85. If a person commits a crime believing his or her acts are lawful in light of 

his or her religious beliefs, do you believe that person is: _____ Guilty of a crime

_____ Not guilty of a crime Please explain. ___________________________________________________________ ___________________________________________________________ 86. Do you believe it is proper for an American citizen to become involved in 

political causes affecting foreign countries? Yes _____ No _____ Please explain. ___________________________________________________________ ___________________________________________________________ 

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21

87. Have you read about, visited, or formed impressions or opinions about the 

following countries? Libya Sudan

Egypt Saudi Arabia

Iran Iraq

Israel Palestine

Kuwait Syria

Afghanistan Arab Emirates

Serbia Bosnia and Herzegovina Yes _____ No _____ If yes, please explain. Use the following side of the page if necessary. ___________________________________________________________ ___________________________________________________________ 88. Have you ever traveled outside the United States? Yes _____ No _____ If yes, please explain where and when. ___________________________________________________________ ___________________________________________________________ 89. Have you ever disagreed with the policies or actions of the United States 

government? Yes _____ No _____ Please explain. ___________________________________________________________ ___________________________________________________________ 90. Some of the defendants in this case are of Arab descent.

(a) Are you or is any relative or close friend of Arab descent? Yes _____ No _____

(b) Have you worked with any people of Arab descent? Yes _____ No _____

(c) Do you socialize with any people of Arab descent? Yes _____ No _____

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(d) Have you ever had a negative experience with a person of Arab descent? Yes _____ No _____ If yes, please explain. _____________________________________________________ (e) Do you have any negative feelings or opinions about people of Arab 

descent? Yes _____ No _____ If yes, please explain. _____________________________________________________ _____________________________________________________ 91. Do you believe that there is a law enforcement bias for or against people of 

Arab descent or people of the Islamic faith? Yes _____ No _____ If yes, please explain. ___________________________________________________________ ___________________________________________________________ 92. 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 _____

93. (a) Is there any reason that you could not be completely fair and impartial to the defendants in this case? Yes _____ No _____

(b) Is there any reason that you could not be completely fair and impartial to the Government in this case? Yes _____ No _____ If you answered either part of the question “yes,” please explain. ___________________________________________________________ ___________________________________________________________ 

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94. Is there any matter not covered by this questionnaire that you feel you 

should tell us about? Yes _____ No _____ If yes, please explain. ___________________________________________________________ ___________________________________________________________ 95. If the choice were solely up to you, would you want to serve on the jury in 

this case? Why or why not? ___________________________________________________________ ___________________________________________________________

___________________________________________________________ 

383