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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA,

Plaintiff,

v.

JEHOADDAN WILSON,

Defendant.

Case No. 17-cr-00028-JST-1 

ORDER RE: CONDUCTING A TRIAL; 

COURT’S INTENDED JUROR 

QUESTIONNAIRE

Re: ECF No. 242

This case is currently scheduled for a pretrial conference on February 5, 2021 and a trial on 

March 1, 2021. 

The Court will distribute a jury questionnaire to potential jurors in advance of voir dire so 

that the questioning of jurors can be done as efficiently as possible. Below is the proposed 

questionnaire, based in part on the Government’s suggested voir dire questions. ECF No. 249. 

The parties shall review the proposed questionnaire and be prepared to present any 

objections to the draft questionnaire at the pretrial conference.

IT IS SO ORDERED.

Dated: February 2, 2021

______________________________________

JON S. TIGAR

United States District Judge

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JUROR QUESTIONNAIRE - INSTRUCTIONS

These questions are designed to obtain information about you as a possible juror in a 

pending case. Filling out the questionnaire online will substantially shorten the process of jury 

selection. 

Please respond to the following questions as completely as possible. You will be given an 

opportunity to explain or expand your answers at jury selection.

Where you feel your answer might invade your right to privacy or be embarrassing to you, 

you may indicate this by placing your initials in the answer box. The judge will then give you an 

opportunity to explain your request privately, with only the judge, the attorneys, and the court 

reporter present. 

Because this questionnaire is part of the jury selection procedure, you must answer the 

questions under penalty of perjury, and you must fill out the answers by yourself, without help 

from any other person. Please do not discuss this case or the questionnaire with anyone. 

As you answer the questions that follow, please keep in mind that there are no “right” or 

“wrong” answers. 

Thank you for your cooperation.

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JUROR QUESTIONNAIRE

Biography

1. Your name: 

2. Your age: 

3. The city or town where you live: 

How long have you lived there: 

4. Your place of birth: 

5. Do you rent or own your own home? 

6. If called to serve as a juror, how will you commute to the courthouse:

___ public transportation ___ car share ___ personal vehicle 

 

___ other (please specify: _____________) 

7. Your marital status: 

___ single ___ married ___ live with partner ___ separated 

 

___ divorced ___ widowed

8. Please describe your educational background: 

Highest grade completed: 

College and/or vocational schools you have attended:

Major areas of study: 

9. Is English your first language? If no, what is your first language? 

Employment

10. What is your current employment status? (e.g. working full-time, unemployed – looking 

for work, unemployed – not looking for work, homemaker, full-time student, etc.)

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11. What is your occupation, and how long have you worked in it? (If you are retired or 

unemployed, please describe your main occupation when you were working.)

12. Who is (or was) your employer?

13. How long have you worked (or did you work) for this employer? 

14. Please list the occupations of any adults you live with:

15. If you have children, please list their ages and sex and, if they are employed, please give 

their occupations:

16. Have you ever worked (1) for the IRS; (2) as a tax preparer; or (3) as a tax attorney? 

Yes:_____ No:_____

If yes, please explain: 

General Background

17. Where do you get your news? (websites, social media, newspapers, magazines, radio 

stations, etc.) What specific websites, newspapers, social media, etc. do you use?

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18. Do you, or anyone close to you belong to, volunteer with, or contribute to any clubs, civic 

or religious organizations, special interest groups and/or charitable organizations? If yes, 

please provide details. 

19. Do you have any bumper stickers on your car? If yes, please describe. 

Health

20. Do you have any physical or emotional disability, impairment, or condition that would 

interfere with your ability to hear, see, or pay attention to the evidence in this case?

Yes:_____ No:_____ If yes, please explain: ______________________________

21. If called to serve as a juror, how concerned are you about getting sick with COVID-19?

Very concerned:_____ Somewhat concerned:_____ Not concerned:_____

22. If called to serve as a juror, how comfortable are you being in a very large courtroom with 

20-30 people, assuming that everyone is wearing a mask and practicing physical 

distancing?

Very uncomfortable:_____ Somewhat uncomfortable:_____ 

Moderately comfortable:_____ Very comfortable:_____

23. How often do you wear a mask in indoor spaces when away from your home?

Never:_____ Some of the time:_____ Most of the time:_____ Always:_____

Experience with the Legal System and U.S. Government

24. This is a prosecution brought by the United States government against the defendant. Do 

you have any opinions about the United States government in general, either positive or 

negative, that might make it difficult for you to be a fair and impartial juror in this case?

Yes:_____ No:_____

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If yes, please tell us about your feelings and opinions and why you believe they might 

affect your ability to be fair and impartial: 

25. Have you ever served on a jury before? ________ How many times?________

If yes: State/County Court _______ Federal Court _______

When? 

Was it a civil or criminal case? 

Were you the foreperson? 

Without saying what the verdict was, did the jury(ies) reach a verdict? 

Is there any reason that your prior jury service would affect your ability to be fair, 

objective, and impartial to both sides here?

Yes:_____ No:_____

26. Have you ever testified in a criminal case? Yes:_____ No:_____

Was it a civil or criminal case? 

In what capacity did you testify – as a witness, victim, defendant, expert, or other?

Is there any reason that this experience would affect your ability to be fair, objective, and 

impartial to both sides here?

Yes:_____ No:_____

27. Have you, or a close friend or family member, ever worked for any court or for any 

prosecution or criminal defense office, including a district attorney’s office, United States 

Attorney’s Office, public defender’s office, or a private criminal defense attorney’s office?

Yes:_____ No:_____

If yes, provide details:

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Is there any reason that your prior jury service would affect your ability to be fair, 

objective, and impartial to both sides here?

Yes:_____ No:_____

28. Have you, or a close friend or family member, ever studied or practiced law?

Yes:_____ No:_____

If yes, provide details.

29. Have you, or a close friend or family member, ever been employed by any law 

enforcement agency?

Yes:_____ No:_____

If yes, provide details.

30. Have you ever applied to serve in the law enforcement or the military?

Yes:_____ No:_____

If yes, provide details.

31. Have you, or a close friend or family member, ever been the victim of or a witness to a 

crime?

Yes:_____ No:_____

If yes, please explain: 

Was anyone arrested and/or charged with committing the crime of which you were a 

victim? Yes:_____ No:_____

If so, how do you feel you were treated by law enforcement officers, prosecutors, defense 

attorneys, and the courts during this case?

Is there anything about your experience that might affect your ability to be a fair and 

impartial juror in this case?

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32. Have you, or a close friend or family member, ever been accused, arrested or convicted of 

any offense? 

Yes:_____ No:_____

If yes, please explain: 

How was the arrest or the charge[s] resolved?

Is there anything about your experience that has caused you any feelings regarding law 

enforcement that might make it difficult for you to be a fair and impartial juror in this 

case?

33. Have you, or a close friend or family member, ever had any negative experience with a 

court or any law enforcement officer or federal agent that would affect your ability to be 

fair and impartial in this case?

Yes:_____ No:_____

If yes, what was the nature of that experience? 

Why do you think it would affect your ability to be fair and impartial? 

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34. Have you ever had an unpleasant experience in court or involving a judge, prosecutor, or 

defense attorney?

Yes:_____ No:_____

If yes, please explain: 

35. Do you have any feelings regarding the criminal justice system that might affect your 

ability to consider the evidence in this case fairly and impartially, and to base your verdict 

only on the evidence presented in this case?

Yes:_____ No:_____

If yes, please explain: 

36. Do you have any opinion regarding law enforcement officers, agents, or employees of the 

Internal Revenue Service and other federal agencies that would affect your ability to fairly 

and impartially evaluate the credibility of the officer, like any other witness, simply 

because he or she is an officer?

Yes:_____ No:_____

If yes, please explain: 

37. Do you believe law enforcement officers are either more or less likely to tell the truth than 

other witnesses because of their occupations?

Yes:_____ No:_____

If yes, please explain: 

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38. Do you have any feelings or opinions about people accused of crimes that would make it 

difficult for you to accord for the defendant the presumption of innocence and require the 

government to prove her guilt beyond a reasonable doubt?

Yes:_____ No:_____

If yes, please explain: 

39. Have you, or a close friend or family member, ever made or filed a claim against the 

United States or any agency of the United States?

Yes:_____ No:_____

If yes, please explain the nature of the claim and its current status: 

Is there anything about your experience or knowledge of this event that could cause you to 

have any bias or animosity toward law enforcement agents, the government in general, or 

the prosecution team in this case?

40. Have you had any dealing whatsoever with the United States Government in connection 

with which you feel that the government did not give you fair treatment?

Yes:_____ No:_____

If yes, please explain: 

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41. Have you, or has any close friend or family member, had any contact with the Internal 

Revenue Service?

If yes, please explain: 

Do you feel that you or your family member or friend was treated fairly by the office or 

agency?

Yes:_____ No:_____

42. Have you, or has any close friend or family member, ever had had personal experiences, 

including being audited by the Internal Revenue Service or a state taxing authority, that 

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

43. Do you have any disagreement with any U.S. criminal law or tax law?

Yes:_____ No:_____

If yes, please identify which laws and why you disagree with them: 

Do these feelings or opinions apply to all types of federal laws, or just certain ones?

Knowledge of the Case

44. The indictment in this case charges Jehoaddan Wilson with one count of conspiracy to file 

false claims, in violation of 18 U.S.C. § 286; six counts of filing a false claim, in violation 

of 18 U.S.C. § 287; six counts of wire fraud, in violation of 18 U.S.C. § 1343; and, six 

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counts of aggravated identity theft, in violation of 18 U.S.C § 1028A. The indictment 

charges the defendant with preparing and submitting fraudulent 2011 federal income tax 

returns in the names of others and asking the IRS to deposit portions of the refunds into her 

own bank account. The aggravated identity theft counts assert that the defendant 

knowingly used another person’s identification in relation to the enumerated felony of wire 

fraud when she used clients’ names and Social Security numbers to file false returns.

Is there anything about the nature of the charges in this case that would prevent you from 

deciding this case fairly?

Yes:_____ No:_____

If yes, please explain: 

45. Have you heard, seen, or read anything from any source about this case?

Yes:_____ No:_____

If yes, please describe the source and substance of what you’ve heard, seen, or read: 

Have you formed any opinions about this case based on what you’ve heard, seen, or read: 

Is there anything about your knowledge about this case that would prevent you from 

following the Court’s instructions to determine the defendant’s guilt or innocence based 

only on the evidence produced in this trial?

Yes:_____ No:_____

If yes, please explain: 

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Knowledge of the Parties

46. To your knowledge, do you or anyone close to you, including family members or friends, 

know any of the following individuals, or any of their family members:

_____ Judge Jon Tigar, the judge in the case, or any member of his staff

_____ Robert David Rees, prosecutor

_____ Alexis Jane Loeb, prosecutor

_____ Kristina Green, prosecutor

_____ Meredith Blagden Osborn, prosecutor

_____ Any employee of the United States Attorney’s Office

_____ Jehoaddan Wilson

_____ Anyone in Jehoaddan Wilson’s family

_____ Robert Frederick Waggener, Jehoaddan Wilson’s defense attorney

_____ John J. Jordan, Jehoaddan Wilson’s defense attorney

_____ Junius Winters 

_____ Wayne Brown

_____ Amjad Qaqish 

_____ Jeanette Cruz

_____ Lisa Cruz

_____ Shamar Dunlap

_____ Shaun Kong 

_____ Steve Martins

_____ Brenda Loston

_____ Maridehl Mather

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_____ Cindy Lin 

_____ Florinda Nivens

_____ Renee Perez 

For anyone for whom you checked “yes,” please list the name and how you know that 

person: 

47. The defendant, attorneys and witnesses may be of various races, ethnicities, national 

origins, or religions, and may have various lifestyles or socioeconomic statuses. Would 

the race, ethnicity, national origin, religion, or socioeconomic status of the defendant, the 

attorneys, or the witnesses make it difficult for you to be a fair juror or in any way affect 

your judgment or the weight and credibility you would give a person’s testimony?

Yes:_____ No:_____

Legal Principles and Ability to Deliberate

48. The Court will instruct you that, in a criminal case, the burden of proof is on the 

prosecution. This burden never shifts to the defendant. The defendant is innocent and 

cannot be proven guilty unless the jury unanimously decides that her guilt has been proven 

beyond a reasonable doubt. Will you follow these rules of law?

Yes:_____ No:_____

If no, please explain: 

If, after hearing all of the evidence, you thought the defendant was probably guilty, but 

also believed the prosecution did not prove its case beyond a reasonable doubt, would you 

have any trouble voting not to convict the defendant?

Yes:_____ No:_____

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If, after hearing all of the evidence, you believe the prosecution has proved that the 

defendant is guilty beyond a reasonable doubt, would you have any trouble voting to 

convict the defendant?

Yes:_____ No:_____

49. The defendant in this case has been charged with crimes in an Indictment. The fact that a 

defendant has been charged with a crime by Indictment is entitled to no weight in your 

analysis. Do you think that because the defendant has been charged here she must have 

done something wrong?

Yes:_____ No:_____

Does the fact that the defendant has been charged with crimes and must now stand trial 

affect your view now about whether or not the defendant is presumed innocent?

Yes:_____ No:_____

50. In a criminal case, you will be instructed that a defendant has an absolute right not to 

testify, and the lack of testimony cannot be held against her in any way. Will you follow 

this law?

Yes:_____ No:_____

If no, please explain: 

If the defendant decides not to testify in this case, would you have any trouble presuming 

that she is innocent, and that her decision not to testify is consistent with being innocent?

Yes:_____ No:_____

If the defendant does not testify in this case, might you in any way relieve the government 

of its burden of proving guilt with evidence beyond a reasonable doubt?

Yes:_____ No:_____

51. As a member of the jury, the Court will instruct you on what the law is and that you must 

apply that law in this case even if you do not personally agree with it. It is important that 

the law is applied to everyone in the same way. Do you believe that, for any reason, you 

would not be able to follow the instructions of the Court? 

Yes:_____ No:_____

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If yes, please explain: 

Would you be able to apply the law given to you by the Court, even if you believe the law 

should be different?

Yes:_____ No:_____

52. The Court will instruct you on the law you must follow in rendering a verdict in this case. 

Is there anything that would prevent you from following the law as the Court instructs?

Yes:_____ No:_____

If yes, please explain: 

53. Do you understand that the Court will instruct you on the law, but that you, as jurors, are 

the exclusive judges of the facts? 

Yes:_____ No:_____

54. Is there anything about your political beliefs or affiliations in general that could prevent 

you from following the law as the Court instructs you or reaching a verdict based solely on 

the evidence you receive at trial?

Yes:_____ No:_____

If yes, please explain: 

55. The parties anticipate that this trial will last approximately two weeks. Would jury service 

on a matter of that length cause a severe and unavoidable hardship to you?

Yes:_____ No:_____

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If yes, please explain: 

56. Do you have any personal or religious beliefs that would make it difficult or impossible for 

you to render a fair and impartial verdict? For example, do your religious or other beliefs 

prevent you from sitting in judgment of others?

Yes:_____ No:_____

Do you have any reservations about sitting in judgment of any person and returning a 

verdict?

Yes:_____ No:_____

57. As a juror, you will be required to take an oath that neither sympathy nor prejudice will 

affect the outcome of your verdict. Can you remain impartial in judging the evidence and 

follow the instructions and laws of the Court and not allow sympathy for or against the 

government or sympathy for or against the defendant to influence your verdict?

Yes:_____ No:_____

58. If you are selected as a juror in this case, will you be able to hear the evidence, deliberate 

with your fellow jurors, and apply the law as the Court instructs you on it without 

speculating about whatever punishment may or may not be imposed in this case?

Yes:_____ No:_____

59. Knowing what you now know about this case, do you have any reservations about your 

ability to hear the evidence, deliberate and return a fair and impartial verdict?

Yes:_____ No:_____

60. Can you think of any other matter that might have some bearing on your qualifications as a 

juror or on your ability to render a fair and impartial verdict based solely on the evidence 

and the judge’s instructions on the law?

Yes:_____ No:_____

If yes, please explain: 

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61. JUROR’S OATH:

I declare under penalty of perjury that my answers to 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 this questionnaire.

Name:

Date:

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ADDITIONAL INFORMATION

(Use this area to provide additional information in response to any prior question)

Question Number(s): _________

Additional information: ___________________________________________________________

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